Background
Charetta Pride and Brittany Reynolds, who were in a relationship and knew each other from work, gave competing accounts of a July 8, 2025 argument at Reynolds’s apartment. Reynolds testified that Pride began fighting and damaging the apartment, including breaking a television, pulling a shelf from a wall, scattering medication and clothes, and spilling perfume. Reynolds said she did not consent to the damage.
Reynolds also testified that Pride refused to leave and punched her in the stomach while Reynolds was recovering from surgery. Pride testified that Reynolds became angry after the two had been drinking at bars, and that the shelf came down accidentally and Reynolds threw the bottle that damaged the television.
After a bench trial, the Hamilton County Municipal Court found Pride guilty of criminal damaging and, on an assault charge, the lesser-included offense of disorderly conduct.
The Court’s Holding
The First District affirmed both convictions. Reynolds’s testimony, the photographs of the damaged apartment, and her immediate 9-1-1 report were sufficient evidence that Pride knowingly created a substantial risk of physical harm to Reynolds’s property without consent. The trial court was entitled to credit Reynolds’s account over Pride’s.
The court also held that Reynolds’s testimony that the punch hurt supplied sufficient evidence of the inconvenience, annoyance, or alarm required for disorderly conduct. A physical effect can establish inconvenience under the statute. The competing testimony did not make either conviction contrary to the manifest weight of the evidence.
Key Takeaways
- An owner’s testimony denying consent, combined with an immediate police report, can establish lack of consent for criminal damaging.
- Knowledge may be inferred from the circumstances, including the nature and extent of property damage.
- Testimony that a punch caused pain can support disorderly conduct’s inconvenience element.
Why It Matters
The decision underscores the deference appellate courts give factfinders on witness credibility in bench trials. Conflicting accounts alone do not establish that a conviction lacks sufficient evidence or is against the manifest weight of the evidence.