Kevin L. Leffel


The analysis that follows focuses on two points. First, many reviewing courts in Ohio have failed to discern between reversing a conviction because it was against the manifest weight of the evidence and reversing because the evidence was not sufficient to support the conviction. The concepts and associated standards of review are separate and distinct. Jenks failed to clarify the distinction and may actually add to the confusion. Second, the elimination of the circumstantial evidence rule has implications concerning the definition of reasonable doubt in Ohio.