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State v. Pride

2026-08-26

Summary

Holding. The appellate court affirmed the trial court's judgments, holding that Pride's convictions for criminal damaging and disorderly conduct were supported by sufficient evidence and were not against the manifest weight of the evidence.

Charetta Pride was tried on charges of assault and criminal damaging after an altercation in Brittany Reynolds's apartment caused significant damage. Reynolds testified that Pride began destroying the apartment without provocation and punched her in the stomach; Pride claimed the damage was accidental and occurred while she was collecting her belongings after Reynolds became jealous at a bar. The trial court found Pride guilty of criminal damaging and the lesser-included offense of disorderly conduct (rather than the original assault charge).

On appeal, Pride challenged the sufficiency and manifest weight of the evidence for both convictions. The appellate court rejected both challenges, finding that Reynolds's testimony, corroborated by photographs of the damage and a 9-1-1 recording, provided sufficient evidence that Pride acted knowingly. The court also found no basis to override the trial court's credibility determination favoring Reynolds's account of events. Because the evidence supported all elements of the crimes and the trial court's factual findings were not clearly erroneous, the convictions were upheld.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether sufficient evidence supported Pride's criminal damaging conviction
  • Whether the criminal damaging conviction was against the manifest weight of the evidence
  • Whether sufficient evidence established that Pride's punch caused 'inconvenience, annoyance, or alarm' required for disorderly conduct
  • Whether the disorderly conduct conviction was against the manifest weight of the evidence

Procedural posture

Pride appealed her criminal damaging and disorderly conduct convictions from a bench trial in Hamilton County Municipal Court.

Authorities cited

Opinion

majority opinion

[Cite as State v. Pride, 2026-Ohio-3328.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250686

TRIAL NOS. 25/CRB/11520/A

Plaintiff-Appellee, : 25/CRB/11520/B

vs. :

CHARETTA PRIDE, : JUDGMENT ENTRY

Defendant-Appellant. :

This cause was heard upon the appeal, the record, and the briefs.

For the reasons set forth in the Opinion filed this date, the judgments of the trial court are affirmed.

Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs be taxed under App.R. 24.

The court further orders that (1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and (2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk:

Enter upon the journal of the court on 8/26/2026.

Pursuant to App.R. 30, the clerk is directed to send all parties, or their counsel if represented, a copy of the court’s judgment and note such action on the docket.

By:_______________________

Administrative Judge

[Cite as State v. Pride, 2026-Ohio-3328.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250686

TRIAL NOS. 25/CRB/11520/A

Plaintiff-Appellee, : 25/CRB/11520/B

vs. :

CHARETTA PRIDE, : OPINION

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Municipal Court

Judgments Appealed From Are: Affirmed

Date of Judgment Entry on Appeal: August 26, 2026

Emily Smart Woerner, City Solicitor, Susan M. Zurface, Chief Prosecuting Attorney, and Robert E. Rickey, Assistant Prosecuting Attorney, for Plaintiff-Appellee,

Angela W. Chang, Hamilton County Public Defender, and Christine Y. Jones, Assistant Public Defender, for Defendant-Appellant.

[Cite as State v. Pride, 2026-Ohio-3328.]

NESTOR, Judge.

{¶1} This case involves two competing accounts of an argument that left an

apartment in shambles. According to Brittany Reynolds, Charetta Pride began tearing

up Reynolds’s apartment without provocation. According to Charetta Pride, Brittany

Reynolds started an argument at a bar because she thought Pride was flirting with

another woman.

{¶2} However the dispute began, it ended with Reynolds’s apartment in

disarray, and two criminal charges filed against Pride. Following a bench trial, the

court found Pride guilty of criminal damaging and disorderly conduct. She now

appeals her convictions, challenging the sufficiency and manifest weight of the

evidence.

{¶3} Because we hold that Pride’s convictions were supported by sufficient

evidence and were not against the manifest weight of the evidence, we affirm the

judgments of the trial court.

I. Factual and Procedural History

{¶4} Defendant-appellant Charetta Pride was charged with one count of

assault, in violation of R.C. 2903.13, and criminal damaging, in violation of R.C.

2909.06. The matter proceeded to a bench trial, where the trial court found Pride

guilty of criminal damaging. On the assault charge, the trial court found Pride guilty

of the lesser-included offense of disorderly conduct, in violation of R.C. 2917.11.

{¶5} The conduct giving rise to Pride’s charges occurred on the evening of

July 8, 2025, when Pride became involved in an argument with Brittany Reynolds.

Both Reynolds and Pride testified at trial. The two provided different versions of the

evening’s events.

{¶6} Reynolds testified that she knew Pride from work. According to

OHIO FIRST DISTRICT COURT OF APPEALS

Reynolds, Pride came over to her house on July 8 “[j]ust to hang out.” She alleged that

Pride had had a few drinks. The two were going to watch a movie, when Pride

“start[ed] going crazy . . . fighting, arguing, tearing up [Reynolds’s] house.” Reynolds

testified that she did not know what started the argument.

{¶7} Reynolds described the damage that Pride caused to her apartment. She

alleged that Pride broke her television, ripped a shelf off of the wall, and dumped out

her medication that Reynolds was taking for a bariatric stomach procedure she

recently underwent. She also stated that Pride dumped perfume on the floor and

threw her clothes everywhere. Reynolds testified that she did not give Pride

permission for any of the above-described destruction. The State admitted photos of

Reynolds’s apartment depicting the damage into evidence.

{¶8} Reynolds testified that she asked Pride to leave. Pride refused and,

knowing that Reynolds was recovering from surgery, punched her in the stomach.

Reynolds then called the police in order to get Pride to stop. Pride left after Reynolds

called 9-1-1. An audio recording of the 9-1-1 call was admitted into evidence.

{¶9} On cross-examination, Reynolds admitted that she and Pride were in a

relationship.

{¶10} Pride offered a different version of events. In her testimony, she stated

that the two were in a relationship and visited a few bars together on July 8. Pride

alleged that Reynolds became angry with her because Reynolds thought that Pride was

“flirting with some lady.” Pride stated that both Reynolds and Pride had been drinking

that night and were both intoxicated.

{¶11} Pride testified that once the two returned to the apartment, she began

to collect her things. Pride stated that while she “still had her place in Amelia,” she

was “basically living” at Reynolds’s apartment.

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OHIO FIRST DISTRICT COURT OF APPEALS

{¶12} Pride insisted that she did not intentionally damage Reynolds’s

property. She explained that the shelf was knocked off the wall by accident, and that

Reynolds threw a water bottle at her, which missed, and damaged the television.

{¶13} The trial court found Pride guilty of criminal damaging and disorderly

conduct. Pride appeals her convictions.

II. Analysis

{¶14} In her first assignment of error, Pride alleges that her conviction for

criminal damaging was based on insufficient evidence and was against the manifest

weight of the evidence. Pride’s second assignment of error challenges the sufficiency

and manifest weight of the evidence supporting her disorderly conduct conviction.

{¶15} A challenge to the sufficiency of the evidence requires appellate courts

to “review the evidence in a light most favorable to the prosecution to determine

whether a rational trier of fact could have found all the essential elements of a crime

beyond a reasonable doubt.” State v. Murphy, 2023-Ohio-2853, ¶ 5 (1st Dist.), citing

State v. Sims, 2015-Ohio-4996, ¶ 7 (1st Dist.). “Whether the evidence is sufficient for

a conviction is a question of law to be reviewed de novo.” Id., citing State v. Ellison,

2008-Ohio-5282, ¶ 9 (1st Dist.). Sufficiency tests whether the State met its burden of

production. State v. Stenson, 2026-Ohio-2280, ¶ 54 (1st Dist.), citing State v. Hicks,

2023-Ohio-2209, ¶ 8 (1st Dist.).

{¶16} In contrast, “a manifest-weight-of-the-evidence challenge looks to

whether the State met its burden of persuasion.” State v. Reillo, Slip Opinion No.

2026-Ohio-2701, ¶ 24, citing State v. Messenger, 2021-Ohio-2044, ¶ 44-45 (10th

Dist.). The manifest weight of the evidence standard refers to whether there is a

“‘greater amount of credible evidence . . . to support one side of the issue rather than

the other.’” (Emphasis added in Thompkins.) Id. at ¶ 25, quoting State v. Thompkins,

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OHIO FIRST DISTRICT COURT OF APPEALS

78 Ohio St.3d 380, 387 (1997). When deciding whether a judgment entered by the

trial court is against the manifest weight of evidence, the appellate court “‘must always

be mindful of the presumption in favor of the finder of fact.’” Id. at ¶ 28, quoting

Eastley v. Volkman, 2012-Ohio-2179, ¶ 21. This is an exceptional remedy that we

reserve for cases where “‘the evidence weighs heavily against the conviction.’” State v.

Cook, 2024-Ohio-4771, ¶ 27 (1st Dist.), citing Thompkins at 387.

A. Criminal Damaging

{¶17} To convict Pride of criminal damaging, the State was required to prove

that Pride “knowingly” created “a substantial risk of physical harm” to Reynolds’s

property without Reynolds’s consent. R.C. 2909.06(A). Physical harm to property is

defined as “any tangible or intangible damage to property that . . . results in loss to its

value or interferes with its use or enjoyment.” R.C. 2901.01(A)(4).

{¶18} In attacking the sufficiency of the evidence supporting her criminal

damaging conviction, Pride first argues that the residence was a “shared living space,”

and therefore, she had consent to use the property. This argument fails. Reynolds’s

testimony established that the residence was hers, and that she did not give Pride

consent to damage her property. Further, Reynolds called 9-1-1 and immediately

reported the damage. When a property owner “immediately reports damage to the

police and testifies that [they] did not consent to the damage, the state proves lack of

consent.” State v. Robinson, 2023-Ohio-2312, ¶ 25 (1st Dist.), citing State v. Baldwin,

2011-Ohio-4988, ¶ 17-18 (9th Dist.).

{¶19} Pride next argues that the evidence failed to show that she acted

knowingly. “A person acts knowingly, regardless of purpose, when the person is aware

that the person’s conduct will probably cause a certain result.” R.C. 2901.22(B).

However, “[c]ulpable mental states are frequently demonstrated through

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OHIO FIRST DISTRICT COURT OF APPEALS

circumstantial evidence.” State v. Thomas, 2025-Ohio-1767, ¶ 22 (2d Dist.), quoting

State v. Hypes, 2019-Ohio-4096, ¶ 21 (2d Dist.). “A defendant’s state of mind may be

inferred from the totality of the circumstances.” Id., citing State v. Murphy, 2018-Ohio-3506, ¶ 16 (2d Dist.).

{¶20} The totality of the circumstances here supports the trial court’s finding

that Pride acted knowingly. Considering the evidence in the light most favorable to

the State, Reynolds’s testimony coupled with the photographs of the apartment

indicate that Pride was aware that her conduct would cause damage.

{¶21} Therefore, we hold that Pride’s criminal damaging conviction was

supported by sufficient evidence.

{¶22} Pride also challenges the manifest weight of the evidence supporting her

conviction. She argues that Reynolds was not a credible witness because she was

“evasive” in her testimony regarding the status of their relationship.

{¶23} We disagree. Reynolds’s characterization of her relationship with Pride

does not demolish her credibility. The trial court, in its role as the fact finder, believed

Reynolds’s version of events over Pride’s. Being “‘mindful of the presumption in favor

of the finder of fact,’” we defer to that finding. Reillo, Slip Opinion No. 2026-Ohio2701, at ¶ 28, quoting Eastley, 2012-Ohio-2179, at ¶ 21.

{¶24} This is not an exceptional case where “the evidence weighs heavily

against the conviction.” See Cook, 2024-Ohio-4771, at ¶ 27 (1st Dist.). Pride’s criminal

damaging conviction was not against the manifest weight of the evidence.

{¶25} Having found that Pride’s criminal damaging conviction was supported

by sufficient evidence and was not against the manifest weight of the evidence, we

overrule the first assignment of error.

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OHIO FIRST DISTRICT COURT OF APPEALS

B. Disorderly Conduct

{¶26} Pride’s second assignment of error challenges the sufficiency and weight

of the evidence supporting her disorderly conduct conviction. Pride was initially

charged with assault. Following the bench trial, Pride was found guilty of disorderly

conduct, which is a lesser-included offense of assault.

{¶27} To support a disorderly conduct conviction, the State had to prove that

Pride “recklessly cause[d] inconvenience, annoyance, or alarm to another by . . .

[e]ngaging in fighting, in threatening harm to persons or property, or in violent or

turbulent behavior.” R.C. 2917.11(A).

{¶28} Pride was convicted of disorderly conduct for allegedly punching

Reynolds in the stomach. In challenging the sufficiency of the evidence, Pride argues

that the State failed to show that the alleged punch caused “inconvenience, annoyance,

or alarm.”

{¶29} Pride cites City of Chardon v. Patterson, 2007-Ohio-1769 (11th Dist.),

for the proposition that “‘[a]nnoyance and alarm are each mental states and, therefore,

are not part of the concept of physical harm.’” Id. at ¶ 41, quoting State v. Neal, 1998

Ohio App. LEXIS 4149, *19 (10th Dist. Sept. 1, 1998). Therefore, she argues,

Reynolds’s testimony was insufficient to show that the punch caused her annoyance

and alarm.

{¶30} But the Chardon court went on to state that “inconvenience may also

have ‘physical elements.’” Id. In Chardon, the defendant shoved the plaintiff at a gas

station. Id. at ¶ 3. At trial, when asked if the shove caused him to fall, the plaintiff

testified that he “went backward a little bit,” but ultimately did not fall. Id. at ¶ 33-36.

The Chardon court held that because the State failed to elicit any testimony that the

shove caused “inconvenience, annoyance, or alarm,” as required by the statute, the

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evidence was insufficient to sustain defendant’s disorderly conduct conviction. Id. at

39, 42.

{¶31} The facts are different here. Here, Reynolds testified that the punch

hurt. Because “inconvenience may also have ‘physical elements,’” we hold that this

testimony is sufficient to support Pride’s disorderly conduct conviction. See id. at ¶

41.

{¶32} Finally, Pride challenges the manifest weight of the evidence supporting

her disorderly conduct conviction. Pride raises similar arguments as she did to her

criminal damaging conviction. She, again, asks us to believe her version of events over

Reynolds’s version.

{¶33} As explained above, we will not do so. A “conviction [i]s not against the

manifest weight of the evidence merely because the [factfinder] chose to believe the

state’s witnesses over the defense’s witnesses.” State v. Jackson, 2024-Ohio-2728, ¶

17 (1st Dist.), citing State v. Robinson, 2019-Ohio-3144, ¶ 30 (12th Dist.). This is not

one of those cases where the trial court clearly lost its way and created a manifest

miscarriage of justice.

{¶34} The second assignment of error is overruled.

III. Conclusion

{¶35} Having overruled Pride’s assignments of error, we affirm the judgments

of the trial court.

Judgments affirmed.

BOCK, P.J., and MOORE, J., concur.

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