State v. Carlson

Ohio Court of Appeals·Decided September 4, 2026·No. 2025-CA-29·Published

Opinion

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT CHAMPAIGN COUNTY

STATE OF OHIO :

: C.A. No. 2025-CA-29

Appellee :

: Trial Court Case No. 2025 CR 099 v. :

: (Criminal Appeal from Common Pleas JAMES ROBERT CLIFFORD : Court) CARLSON :

: FINAL JUDGMENT ENTRY & Appellant : OPINION

...........

Pursuant to the opinion of this court rendered on September 4, 2026, the judgment of the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately send a copy of the court’s ruling to each party and note that action on the docket. Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note the service on the appellate docket.

For the court,

MARY K. HUFFMAN, JUDGE

EPLEY, J., and HANSEMAN, J., concur.

OPINION

CHAMPAIGN C.A. No. 2025-CA-29

JOHN A. FISCHER, Attorney for Appellant KARA N. RICHTER, Attorney for Appellee

HUFFMAN, J.

{¶ 1} James Robert Clifford Carlson appeals from a judgment entry of conviction on one count each of assault on a peace officer and obstructing official business (“obstruction”). For the following reasons, the judgment of the Champaign County Common Pleas Court is affirmed.

Facts and Procedural History

{¶ 2} On September 3, 2025, Carlson was indicted for assault and obstruction. He was charged in relation to an altercation with sheriff’s deputies who responded to the home of Carlson’s parents on a report that he was experiencing a mental health crisis. A jury trial occurred on November 5, 2025, and the jury found Carlson guilty of both counts in the indictment. The trial court imposed concurrent prison sentences of 18 months for assault and 12 months for obstruction. The court also imposed concurrent fines of $250 on each count. Carlson timely appealed.

Assignments of Error and Analysis Sufficiency and Manifest Weight of the Evidence

{¶ 3} Carlson asserts three assignments of error. We consider his first two assigned errors together. He initially argues that his convictions were not supported by sufficient evidence. According to Carlson, “even viewing the evidence in a light most favorable to the State, it is plain that the State failed to prove that [he] had the requisite mental state to commit” assault and obstruction. He claims that law enforcement “escalated the situation by

attempting to tase [him] and, failing that, immediately rushing to tackle him.” Carlson argues that he “had no time to think” and “reacted instinctively” in order to escape the “gang-tackle.”

{¶ 4} As to the assault offense, Carlson argues that he “only struggled with the officers at the moment he was jumped by them” and did not act knowingly. He claims he “was compliant and did nothing improper or violent against any of the officers.” As to obstruction, Carlson again asserts that he was merely “reacting by instinct not by any planning, and as a result, not with any purpose,” and he claims he “could not be expected to react in any other way.” He analogizes his offense to an innocent bystander being charged with obstruction after being startled by a police officer in pursuit of a suspect on foot and bumping into the officer, thereby allowing the suspect to escape. According to Carlson, “[i]nstinctive reactions should not form the basis of an obstructing-official-business charge.”

{¶ 5} In his second assignment of error, Carlson argues that his convictions were against the manifest weight of the evidence. He claims, again, that he “simply fought back,” because he was “the subject of an unprovoked and unexpected attack.” He directs our attention to the testimony of Detective Brandon Fenwick, which he asserts “shows conclusively that [Carlson] did not initiate the struggle.” Carlson argues that the evidence was clear that he, “while in the throes of a mental health crisis, was attacked out of the blue by three officers in a darkened room after being unsuccessfully tased.” He asserts that “no reasonable jury could conclude” that he assaulted the officers or obstructed official business. He acknowledges that it is “unfortunate” that an officer was injured but argues that he should not be blamed.

{¶ 6} In State v. Thompkins, 78 Ohio St.3d 380 (1997), the Supreme Court of Ohio clarified the distinction between appellate review of the sufficiency of the evidence and appellate review of the weight of the evidence. A sufficiency of the evidence argument

relates to whether the State “presented adequate evidence on each element of the offense to allow the case to go to the jury or sustain the verdict as a matter of law.” State v. Wilson, 2009-Ohio-525, ¶ 10 (2d Dist.), citing Thompkins. “In essence, sufficiency is a test of adequacy. Whether the evidence is sufficient to sustain a verdict is a question of law.” Thompkins at 386.

{¶ 7} The test for sufficiency of the evidence is set forth in State v. Jenks, 61 Ohio St.3d 259 (1991):

An appellate court’s function when reviewing the sufficiency of the evidence to support a criminal conviction is to examine the evidence admitted at trial to determine whether such evidence, if believed, would convince the average mind of the defendant’s guilt beyond a reasonable doubt. 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. at paragraph two of the syllabus. In other words, on review for sufficiency, courts are to assess not whether the State’s evidence is to be believed, but whether, if believed, the evidence against a defendant would support a conviction. Thompkins at 390.

{¶ 8} A weight of the evidence argument, on the other hand, challenges the believability of the evidence and asks which of the competing inferences suggested by the evidence is more believable or persuasive. Wilson at ¶ 12, citing State v. Hufnagel, 1996 WL 501470, *3 (2d Dist. Sept. 6, 1996). The proper test to apply to a manifest weight of the evidence inquiry is set forth in State v. Martin, 20 Ohio App.3d 172, 175 (1st Dist. 1983): “[T]he court, reviewing the entire record, weighs the evidence and all reasonable inferences, considers the credibility of witnesses and determines whether in resolving conflicts in the

evidence, the jury lost its way and created such a manifest miscarriage of justice that the conviction must be reversed and a new trial ordered.”

{¶ 9} “In order to find that a manifest miscarriage of justice occurred, an appellate court must conclude that a guilty verdict is ‘against,’ that is, contrary to, the manifest weight of the evidence presented.” Wilson at ¶ 14, citing State v. McDaniel, 1998 WL 214606 (2d Dist. May 1, 1998). “Typically, in manifest weight review, we defer to trial court decisions on credibility issues, as those courts are in the best position to make that determination.” State v. Curtis, 2020-Ohio-4152, ¶ 20 (2d Dist.), citing State v. Lawson, 1997 WL 476684, *4 (2d Dist. Aug. 22, 1997). Put differently, our review of witness credibility is not de novo. State v. Reillo, 2026-Ohio-2701, ¶ 22.

{¶ 10} “Although sufficiency and manifest weight are different legal concepts, manifest weight may subsume sufficiency in conducting the analysis; that is, a finding that a conviction is supported by the manifest weight of the evidence necessarily includes a finding of sufficiency.” State v. Flores-Lopez, 2017-Ohio-690, ¶ 49 (2d Dist.), citing State v. McCrary, 2011-Ohio-3161, ¶ 11 (10th Dist.); accord State v. Robinson, 2015-Ohio-1167,

¶ 17 (2d Dist.). As a result, “a determination that a conviction is supported by the weight of the evidence will also be dispositive of the issue of sufficiency.” Robinson at ¶ 17, citing State v. Braxton, 2005-Ohio-2198, ¶ 15 (10th Dist.).

{¶ 11} R.C. 2903.13 proscribes assault on a police officer and states in relevant part:

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Related

State v. Martin
485 N.E.2d 717 (Ohio Court of Appeals, 1983)
State v. Braxton, Unpublished Decision (5-5-2005)
2005 Ohio 2198 (Ohio Court of Appeals, 2005)
State v. Wilson, 22581 (2-6-2009)
2009 Ohio 525 (Ohio Court of Appeals, 2009)
State v. Flores-Lopez
2017 Ohio 690 (Ohio Court of Appeals, 2017)
State v. Davenport
2017 Ohio 688 (Ohio Court of Appeals, 2017)
State v. Curtis
2020 Ohio 4152 (Ohio Court of Appeals, 2020)
State v. Jenks
574 N.E.2d 492 (Ohio Supreme Court, 1991)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)
State v. Reillo
Ohio Supreme Court, 2026