Bedford Hts. v. Davis

2024 Ohio 1281, 239 N.E.3d 1145
CourtOhio Court of Appeals
DecidedApril 4, 2024
Docket113060
StatusPublished
Cited by1 cases

This text of 2024 Ohio 1281 (Bedford Hts. v. Davis) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bedford Hts. v. Davis, 2024 Ohio 1281, 239 N.E.3d 1145 (Ohio Ct. App. 2024).

Opinion

[Cite as Bedford Hts. v. Davis, 2024-Ohio-1281.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

CITY OF BEDFORD HEIGHTS, :

Plaintiff- Appellee, : No. 113060 v. :

ROMAINE T. DAVIS, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND VACATED RELEASED AND JOURNALIZED: April 4, 2024

Criminal Appeal from the Bedford Municipal Court Case No. 23CRB00118

Appearances:

Marlene J. Ridenour, Bedford Heights Law Director/ Prosecutor, for appellee.

Cullen Sweeney, Cuyahoga County Public Defender, and Francis Cavallo, Assistant Public Defender, for appellant.

MICHELLE J. SHEEHAN, P.J.:

Defendant-appellant Romaine T. Davis appeals from a judgment of the

Bedford Municipal Court that convicted him of obstructing official business. Davis was stopped by a patrol officer for the city of Bedford Heights (“the city”). During

the traffic stop, Davis would not identify himself or provide his driver’s license. He

was charged with obstructing official business as a result. The offense requires an

affirmative, overt act that hinders a police officer’s duties. Our review of the record,

however, indicates the city presented no evidence that Davis engaged in an

affirmative, overt act during the traffic stop. Finding merit to the appeal, we reverse

the trial court’s judgment and vacate Davis’s conviction of obstructing official

business.

Background

Davis was cited for and convicted of improper display of plate and

obstruction of official business. At trial, the prosecutor elicited the following

testimony from Patrolman Vicent Ellis.

Patrolman Ellis observed Davis traveling in a vehicle without a visible

plate. After he stopped Davis’s vehicle, Davis refused to roll down the window. He

also refused to identify himself or provide his driver’s license despite multiple

requests from Ellis. Davis also requested the presence of Ellis’s supervisor. A

sergeant from the Bedford Heights Police Department then arrived to assist Ellis.

Davis eventually rolled down the window, and the officers were able to read the VIN

number on the vehicle and determine Davis’s identity based on the BMV records.

This is the entirety of Ellis’s testimony.

Davis was cited for improper display of plate and a misdemeanor

offense of obstructing official business. He was sentenced to a fine of $100 plus costs for the traffic offense, and $100 plus costs in addition to a suspended jail term of ten

days for obstructing official business. Davis now appeals from his conviction of

obstruction of official business.

Insufficient Evidence for Obstructing Official Business

Under the first assignment of error, Davis contends there is insufficient

evidence produced at trial to support a finding of guilt on the offense of obstructing

official business. When reviewing a challenge to the sufficiency of the evidence, we

review the evidence admitted at trial and determine whether such evidence, if

believed, would convince the average mind of the defendant’s guilt beyond a

reasonable doubt. State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (1991),

paragraph two of the syllabus. “The relevant inquiry is whether, after viewing the

evidence in a light most favorable to the prosecution, any rational trier of fact could

have found the essential elements of the crime proven beyond a reasonable doubt.”

Id.

Davis was convicted of obstructing official business in violation of

R.C. 2921.31(A), which states, “No person, without privilege to do so and with

purpose to prevent, obstruct, or delay the performance by a public official of any

authorized act within the public official’s capacity, shall do any act that hampers or

impedes a public official in the performance of the public official’s lawful duties.”

The statute requires evidence demonstrating that a defendant acted

with a purpose to impede the performance of an official duty. “The purpose with

which a person does an act is determined from the manner in which it is done, the means used, and all the other facts and circumstances in evidence.” State v. Hardin,

16 Ohio App.3d 243, 245, 475 N.E.2d 483 (10th Dist.1984).

Furthermore, the courts have consistently held that the crime of

obstructing official business requires “‘proof of an affirmative or overt act that

hampered or impeded the performance of the lawful duties of a public official.’”

Parma v. Jackson, 8th Dist. Cuyahoga No. 112646, 2024-Ohio-575, ¶ 11, quoting

Brooklyn v. Kaczor, 8th Dist. Cuyahoga No. 98816, 2013-Ohio-2901, citing Parma

v. Campbell, 8th Dist. Cuyahoga Nos. 79041 and 79042, 2001 Ohio App. LEXIS

4907 (Nov. 1, 2001). See also, e.g., State v. Keagle, 9th Dist. Summit Nos. 29045

and 29056, 2019-Ohio-3975, ¶ 21; State v. Partee, 10th Dist. Franklin Nos. 17AP-

804 and 17AP-805, 2018-Ohio-3878, ¶ 26; State v. Vitantonio, 2013-Ohio-4100,

995 N.E.2d 1291, ¶ 16 (11th Dist.); and State v. Prestel, 2d Dist. Montgomery

No. 20822, 2005-Ohio-5236, ¶ 16.

“‘“One cannot be guilty of obstructing official business by doing nothing

because the text of R.C. 2921.31 specifically requires an offender to act.”’” Jackson

at ¶ 11, quoting Kaczor at ¶ 8, quoting State v. Brickner-Latham, 3d Dist. Seneca

No. 13-05-26, 2006-Ohio-609, ¶ 26. Accordingly, “‘the mere refusal to answer a

police officer’s questions regarding one’s identity cannot support a conviction for

obstructing official business.’” Id., quoting Kaczor at ¶ 8, citing Cleveland Hts. v.

Lewis, 187 Ohio App.3d 786, 2010-Ohio-2208, 933 N.E.2d 1146, ¶ 37 (8th Dist.)

(mere failure to obey a law enforcement officer’s request does not bring a defendant

within the ambit of obstructing official business). See also Prestel at ¶ 16 (obstructing official business requires some affirmative or overt act as opposed to

merely failing or refusing to cooperate or obey a police officer’s request for

information); and State v. McCrone, 63 Ohio App.3d 831, 580 N.E.2d 468 (9th

Dist.1989) (a mere refusal to cooperate with police and provide identification upon

request does not constitute obstructing official business). Similarly, a defendant’s

mere refusal to provide his or her driver’s license to an officer upon request does not

constitute obstructing official business. Kaczor at ¶ 8, citing Middletown v. Hollon,

156 Ohio App.3d 565, 2004-Ohio-1502, 807 N.E.2d 945, ¶ 32 (12th Dist.), citing

McCrone, supra.

In contrast, “‘when one takes overt acts to impede or obstruct the

officer’s investigation or business, one may be found guilty of obstructing official

business.’” Middletown v. Hollon, 156 Ohio App.3d 565, 2004-Ohio-1502, 807

N.E.2d 945, ¶ 33 (12th Dist.), quoting State v. Merz, 12th Dist. Butler No. CA97-05-

108, 2000 Ohio App. LEXIS 3414 (July 31, 2000). See Keagle (sufficient evidence

for obstructing official business existed when the defendant repeatedly refused to

exit his vehicle for the officers to conduct a probable cause search and also verbally

quarrelled with the officers); State v. Moss, 9th Dist.

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Bluebook (online)
2024 Ohio 1281, 239 N.E.3d 1145, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bedford-hts-v-davis-ohioctapp-2024.