State v. Clay

CourtOhio Court of Appeals
DecidedJune 8, 2026
Docket2025-P-0084
StatusPublished

This text of State v. Clay (State v. Clay) 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
State v. Clay, (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Clay, 2026-Ohio-2136.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT PORTAGE COUNTY

STATE OF OHIO, CASE NO. 2025-P-0084 CITY OF KENT,

Plaintiff-Appellee, Criminal Appeal from the Municipal Court, Kent Division - vs -

REUBEN O. CLAY, Trial Court No. 2025 TRC 00716 K

Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: June 8, 2026 Judgment: Affirmed in part, reversed in part, and remanded

Connie J. Lewandowski, Portage County Prosecutor, and Heaven DiMartino, Assistant Prosecutor, 241 South Chestnut Street, Ravenna, OH 44266 (For Plaintiff-Appellee).

Adam M. VanHo, 37 South Main Street, Suite 3, P.O. Box 157, Munroe Falls, OH 44262 (For Defendant-Appellant).

SCOTT LYNCH, J.

{¶1} Defendant-appellant, Reuben Clay, appeals from the judgment of the

Portage County Municipal Court, Kent Division, finding him guilty of OVI, OVI Refusal,

and a lanes of travel violation. For the following reasons, we affirm in part, and reverse

in part the decision of the lower court and remand for further proceedings consistent with

this opinion.

{¶2} On March 31, 2025, Clay was issued a ticket for Operating a Vehicle Under

the Influence of Alcohol, a misdemeanor of the first degree, in violation of R.C.

4511.19(A)(1); Operating a Vehicle Under the Influence of Alcohol-Refusal, a misdemeanor of the first degree, in violation of R.C. 4511.19(A)(2); and a lanes of travel

violation, a minor misdemeanor, in violation of R.C. 4511.25.

{¶3} A bench trial was held on July 29, 2025. Officer Charles Ellis of the Kent

Police Department testified that on March 30, 2025, he observed Clay make a “wide turn,”

turned his patrol vehicle around and then saw that Clay “struck a curb on the west side of

the roadway after making a wider turn at that intersection.” Ellis conducted a traffic stop.

Upon making contact with Clay, Ellis could smell the strong odor of alcoholic beverage

coming from the vehicle, and observed that Clay had bloodshot eyes and slurred speech.

After conducting sobriety tests, Clay was arrested. Ellis testified that he decided to charge

Clay with “Operating a Vehicle Under the Influence, Operating with a Refusal, have to

due to a prior 2022 conviction for OVI, I believe in Summit County Court of Common Pleas

and Lanes of Travel.”

{¶4} David Wilson, Clay’s friend, was his passenger at the time of the traffic stop.

He testified that he did not feel the vehicle hit a curb or notice swerving or erratic driving.

{¶5} The court found Clay guilty of the offenses for which he was charged and

sentenced him to a term of 180 days in jail with 170 suspended. The court stayed the

sentence pending appeal.

{¶6} Clay timely appeals and raises the following assignments of error:

{¶7} “[1.] Appellant’s conviction for operating a vehicle under the influence, in

violation of Section 4511.19(A)(2), is unconstitutional as it is based on insufficient

evidence, in violation of the Fifth and Fourteenth Amendments to the United States

Constitution and Article One, Sections Ten and Sixteen of the Ohio Constitution, and

Section 4511.19(A)(2) of the Ohio Revised Code.”

PAGE 2 OF 14

Case No. 2025-P-0084 {¶8} “[2.] Appellant’s convictions for lanes of travel upon roadways of sufficient

width, in violation of Section 4511.25 of the Ohio Revised Code, is unconstitutional as it

is based on insufficient evidence, in violation of the Fifth and Fourteenth Amendments to

the United States Constitution and Article One, Sections Ten and Sixteen of the Ohio

Constitution, and Section 4511.25 of the Ohio Revised Code.”

{¶9} “[3.] Appellant was deprived of the effective assistance of counsel at trial,

in violation of Strickland v. Washington, the Sixth and Fourteenth Amendments of the

United States Constitution, and Article One, Section Ten of the Ohio Constitution.”

{¶10} In his first assignment of error, Clay argues that his OVI conviction for a

violation of R.C. 4511.19(A)(2) was supported by insufficient evidence demonstrating he

had a prior conviction for OVI within twenty years.

Sufficiency of the Evidence to Demonstrate a Prior OVI Conviction

{¶11} Sufficiency of the evidence is a “term of art meaning that legal standard

which is applied to determine . . . whether the evidence is legally sufficient to support the

jury verdict as a matter of law.” (Citation omitted.) State v. Thompkins, 1997-Ohio-52, ¶

23 (“[i]n essence, sufficiency is a test of adequacy”). “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.” State v.

Jenks, 61 Ohio St.3d 259 (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. “A challenge to the sufficiency of the evidence presents a

PAGE 3 OF 14

Case No. 2025-P-0084 question of law, which on appeal is reviewed de novo.” State v. Dunn, 2024-Ohio-5742,

¶ 28. We observe that while Clay’s counsel initially filed a Crim.R. 29 motion to dismiss

challenging sufficiency following the State’s case, the defense did not renew that motion

after resting its case. This does not, however, impede Clay’s ability to challenge the

sufficiency of the evidence. The Ohio Supreme Court has held that an “[a]ppellant’s ‘not

guilty’ plea preserve[s] his right to object to the alleged insufficiency of the evidence.”

State v. Jones, 2001-Ohio-57, ¶ 48. Further, this court has determined that “[w]here an

appealing party fails to renew a motion for acquittal at the close of evidence, such an

omission does not forfeit or waive his or her right to argue evidential sufficiency on

appeal.” State v. Norman, 2026-Ohio-779, ¶ 45 (11th Dist.).

{¶12} Pursuant to R.C. 4511.19(A)(2), “[n]o person who, within twenty years of

the conduct described in division (A)(2)(a) of this section, previously has been convicted

of or pleaded guilty to a violation of this division . . . shall:” (a) operate a vehicle while

under the influence and (b) subsequent to arrest, refuse to submit to requested testing.

“‘[T]here are three elements of a charge brought pursuant to R.C. 4511.19(A)(2):’ (1) an

OVI conviction within 20 years of the current violation, (2) operation of a motor vehicle

while under the influence of alcohol or drugs, and (3) a refusal to submit to a chemical

test while under arrest for the current OVI.” State v. Varner, 2020-Ohio-1329, ¶ 31 (11th

Dist.), citing State v. Hoover, 2009-Ohio-4993, ¶ 13. “[A] prior OVI conviction in 20 years

is an essential element of R.C. 4511.19(A)(2) that the state must prove beyond a

reasonable doubt.” Varner at ¶ 32.

{¶13} To prove the element of a prior conviction, the State may present proof

under R.C. 2945.75(B). R.C. 2945.75(B)(1) provides: “Whenever in any case it is

PAGE 4 OF 14

Case No. 2025-P-0084 necessary to prove a prior conviction, a certified copy of the entry of judgment in such

prior conviction together with evidence sufficient to identify the defendant named in the

entry as the offender in the case at bar, is sufficient to prove such prior conviction.”

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State v. Clay, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-clay-ohioctapp-2026.