State v. Eley

In State v. Eley (1978), 56 Ohio St.2d 169, 172, 383 N.E.2d 132, 134, the defendant appealed his aggravated robbery conviction involving his wrestling the victim to the ground to steal a bag of money. The defendant claimed that he should not have been convicted of aggravated robbery because the victim had not sustained serious physical injuries. The Eley court upheld the conviction, holding that "a jury could reasonably find that the attacker would not have stopped short of serious physical harm had the victim failed to let go of the money bag." Id. at 172. In other words, "the jury could reasonably conclude, beyond a reasonable doubt, that the assailant attempted to inflict whatever harm was necessary to incapacitate the victim." Id.