Cleveland v. Snyder

2025 Ohio 2986
CourtOhio Court of Appeals
DecidedAugust 21, 2025
Docket114465
StatusPublished

This text of 2025 Ohio 2986 (Cleveland v. Snyder) 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
Cleveland v. Snyder, 2025 Ohio 2986 (Ohio Ct. App. 2025).

Opinion

[Cite as Cleveland v. Snyder, 2025-Ohio-2986.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

CITY OF CLEVELAND, :

Plaintiff-Appellee, : No. 114465 v. :

THOMAS M. SNYDER, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: August 21, 2025

Criminal Appeal from the Cleveland Municipal Court Case No. 2024-TRD-001623

Appearances:

Mark Griffin, Cleveland Director of Law, and Margaret Scott and Desiree Land, Assistant Directors of Law, Aqueelah A. Jordan, Chief Prosecutor, and Aric Kinast, Assistant Prosecutor, for appellee.

Law Offices of Brent L. English and Brent L. English, for appellant.

ANITA LASTER MAYS, J.:

Defendant-appellant Thomas M. Snyder (“Snyder”) appeals his

convictions for violating Cleveland Codified Ordinances (“C.C.O.”) 439.11(A) and (B) and 437.27(B)(1). After a thorough review of the record and applicable law, we

affirm the judgment of the trial court.

I. Factual and Procedural History

On January 25, 2024, Snyder operated a commercial dump truck

hauling rock salt from the Cargill mine in Cleveland. Officer David Walter (“Officer

Walter”), of the Cleveland Police Department’s commercial vehicle enforcement

division, observed Snyder’s truck carrying a visible load of rock salt piled above the

bed’s side rails and lacking a protective cover. Officer Walter followed the vehicle

across the Detroit-Superior Bridge and conducted a traffic stop near West Huron

Road.

Upon inspection, Officer Walter determined that Snyder’s truck

lacked sufficient wheel protectors and that Snyder was not wearing a seatbelt. He

issued citations for:

1. Loads dropping or leaking, in violation of C.C.O. 439.11(A), a third- degree misdemeanor;

2. Inadequate wheel protectors, in violation of C.C.O. 439.09, a minor misdemeanor; and

3. Failure to wear a seatbelt, in violation of C.C.O. 437.27(B)(1), also a minor misdemeanor.

A jury trial was held July 25, 2024, on Count 1, loads dropping or

leaking, in violation of C.C.O. 439.11. The jury subsequently found Snyder guilty.

The trial court separately heard the counts relative to C.C.O. 439.09

and 437.27(B)(1) and found Snyder guilty of inadequate wheel protectors and failure to wear a seatbelt, both minor misdemeanors. Snyder timely appeals, raising the

following assignments of error:

Assignment of Error No. 1

The trial court erred by denying Snyder’s motion for a directed verdict on the charge of violating C.C.O. 439.11(A), as the evidence was legally insufficient.

Assignment of Error No. 2

The trial court erred by denying Snyder’s motion for a directed verdict on the charge of violating C.C.O. 439.11(B), as the evidence was legally insufficient.

Assignment of Error No. 3

The conviction for violating C.C.O. 439.11(A) is against the manifest weight of the evidence.

Assignment of Error No. 4

The conviction for violating C.C.O. 439.11(B) is against the manifest weight of the evidence.

Assignment of Error No. 5

The trial court erred by denying Snyder’s motion for a directed verdict on the charge of violating C.C.O. 437.27(B)(1), as the evidence was legally insufficient.

Assignment of Error No. 6

The conviction for violating C.C.O. 437.27(B)(1) is against the manifest weight of the evidence.

II. Law and Analysis

For ease of analysis, we address the assignments of error together and

out of order where appropriate. A. Standard of Review

Snyder challenges the convictions of C.C.O. 439.11 on sufficiency and

manifest-weight grounds in his first and third assignments of error. When

reviewing the sufficiency of the evidence supporting a criminal conviction, an

appellate court’s function is to examine the evidence admitted at trial and determine

whether, if believed, it would convince the average mind of the defendant’s guilt

beyond a reasonable doubt. State v. Thompkins, 78 Ohio St.3d 380, 386 (1997).

B. Conviction under C.C.O. 439.11(A) Load Dropping or Leaking

C.C.O. 439.11(A) provides in relevant part: “No vehicle shall be driven

or moved on any highway unless the vehicle is so constructed, loaded or covered as

to prevent any of its load from dropping, sifting, leaking or otherwise escaping

therefrom.”

At trial, Officer Walter testified that he observed rock salt visible

above the side rails of Snyder’s truck bed and that the load was not covered with a

tarp or any protective material. Based on his experience in commercial vehicle

enforcement, Officer Walter concluded that the load was susceptible to escape

during operation.

Snyder offered testimony from the truck owner, Jeffrey Kendera, who

indicated the truck was loaded in a typical fashion and that his trucks had never lost

rock salt during transport. However, the jury was entitled to find Officer Walter’s

testimony credible and determine that the visibility of the uncovered load posed a

risk contemplated by the ordinance. The ordinance does not require proof that material escaped the truck;

it is sufficient to show that the truck was not loaded or covered in a manner that

would prevent escape. Here, the jury’s findings were supported by sufficient

competent, credible evidence and satisfied the sufficiency standard.

A challenge to the manifest weight of the evidence questions whether

the trier of fact clearly lost its way in resolving factual disputes, thereby resulting in

a manifest miscarriage of justice. State v. Wilks, 2018-Ohio-1562, ¶ 168, citing State

v. Thompkins, 78 Ohio St.3d 380, 387 (1997). Such a challenge attacks the

credibility and persuasiveness of the evidence presented. State v. Whitsett, 2014-

Ohio-4933, ¶ 26 (8th Dist.), citing Thompkins at ¶ 387. The reviewing court must

examine the entire record, weigh the evidence and all reasonable inferences,

consider the credibility of witnesses, and determine whether the trier of fact clearly

lost its way and created such a manifest miscarriage of justice that the conviction

must be reversed and a new trial ordered. State v. Nicholson, 2024-Ohio-604, ¶ 71.

As the trier of fact, the jury was in the best position to observe the

demeanor of the witnesses and to assess their credibility. See State v. Jordan, 2023-

Ohio-3800, ¶ 26, citing Thompkins at ¶ 387. A reversal on manifest-weight grounds

is reserved for the rare case in which the evidence weighs heavily against the

conviction. Nicholson at ¶ 71.

Accordingly, assignments of error Nos. 1 and 3 are overruled. C. C.C.O. 439.11(B) Unsanitary Load

Snyder challenges his conviction under C.C.O. 439.11(B) in his second

and fourth assignments of error. C.C.O. 439.11(B) provides in relevant part:

Except for a farm vehicle used to transport agricultural produce or agricultural production materials or a rubbish vehicle in the process of acquiring its load, no vehicle loaded with garbage, swill, cans, bottles, waste paper, ashes, refuse, trash, rubbish, waste, wire, paper, cartons, boxes, glass, solid waste or any other material of an unsanitary nature that is susceptible to blowing or bouncing from a moving vehicle shall be driven or moved on any highway unless the load is covered with a sufficient cover to prevent the load or any part of the load from spilling onto the highway.

Although the briefs referenced C.C.O. 439.11(A) and 439.11(B), the

trial court referred to C.C.O.

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Related

State v. Wilks (Slip Opinion)
2018 Ohio 1562 (Ohio Supreme Court, 2018)
State v. Dehass
227 N.E.2d 212 (Ohio Supreme Court, 1967)
State v. Headley
453 N.E.2d 716 (Ohio Supreme Court, 1983)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 2986, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cleveland-v-snyder-ohioctapp-2025.