State v. Fails

2026 Ohio 1107
CourtOhio Court of Appeals
DecidedMarch 30, 2026
Docket1-25-23
StatusPublished

This text of 2026 Ohio 1107 (State v. Fails) 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. Fails, 2026 Ohio 1107 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Fails, 2026-Ohio-1107.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT ALLEN COUNTY

STATE OF OHIO, CASE NO. 1-25-23

PLAINTIFF-APPELLEE,

v.

JEFFERY W. FAILS, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

Appeal from Lima Municipal Court Trial Court No. 24CRB02160-A2

Judgment Affirmed

Date of Decision: March 30, 2026

APPEARANCES:

William T. Cramer for Appellant

Matthew A. Pheneger for Appellee Case No. 1-25-23

ZIMMERMAN, P.J.,

{¶1} Defendant-appellant, Jeffery W. Fails (“Fails”), appeals the April 21,

2025 judgment entry of conviction and sentencing of the Lima Municipal Court.

For the reasons that follow, we affirm.

{¶2} This case stems from a traffic stop of Fails initiated by Officer Amy

Glanemann (“Officer Glanemann”) of the Lima Police Department. During the

early morning hours of November 17, 2024, Officer Glanemann stopped Fails’s

vehicle after observing that the rear license plate light was not properly illuminated.

When Officer Glanemann approached the vehicle, Fails informed her that he did not

have a valid driver’s license. Officer Glanemann returned to her police cruiser to

issue a citation.

{¶3} Shortly thereafter, Officer Justin Wireman (“Officer Wireman”) and

Officer Jacob Cox (“Officer Cox”) of the Lima Police Department arrived on the

scene with a trained dog to conduct an open-air sniff of the stopped vehicle. During

the open-air sniff, Fails was seated in the driver’s seat, with a passenger in the front

seat and another in the back. The dog alerted to the presence of possible narcotics

on the passenger side of the vehicle. An investigation for illegal drugs ensued.

{¶4} Officer Cox instructed Fails to step out of the vehicle. After Officer

Cox conducted a pat-down search for weapons, Fails was led to the front bumper of

Officer Glanemann’s cruiser—which was parked directly behind the stopped

-2- Case No. 1-25-23

vehicle. Fails was told to stay at the bumper of cruiser. Fails argued with the

officers about their investigation and used his phone to record the police encounter.

Officer Cox proceeded to the passenger side of the vehicle.

{¶5} As Officer Cox was removing the front-seat passenger from the stopped

vehicle, Officer Glanemann instructed Fails to stay at the bumper of the police

cruiser. Fails continued to argue with the officers about their investigation. At this

point, Officer Brandon Stephenson (“Officer Stephenson”) of the Lima Police

Department approached Fails, pointed to the police cruiser, and told him to stay at

the bumper. Despite being told multiple times to stay at the bumper of the cruiser,

Fails stepped away from the police cruiser and moved toward Officer Cox at the

passenger side of the stopped vehicle. As Fails was walking toward Officer Cox,

Officer Wireman yelled at Fails to move back to the bumper.

{¶6} Video footage from the dashboard camera of Officer Glanemann’s

cruiser shows Fails stepping away from the bumper and walking toward Officer

Cox. When Fails continued to take steps toward Officer Cox, Officer Stephenson

approached Fails from behind and grabbed his arms. Officer Glanemann then

ordered Fails to put his phone down. Officer Stephenson and Officer Glanemann

attempted to secure Fails in handcuffs, but Fails tensed his arms and pulled against

the officers.

{¶7} At this point, Officer Stephenson used a leg sweep to take Fails to the

ground. On the ground, Fails kept his left arm under his body and refused to put his

-3- Case No. 1-25-23

hands behind his back. Both Officer Cox and Officer Wireman assisted in

restraining Fails to deescalate the situation. The officers forcibly pulled Fails’s left

arm from underneath him and placed both hands behind his back.

{¶8} During the struggle with Fails, the two passengers were outside of the

vehicle and yelling at the officers. Officer Wireman instructed the two passengers

to stay back. After the officers secured Fails in handcuffs, he was placed in the back

of Officer Glanemann’s cruiser. The officers were then able to complete their

investigation.

{¶9} On November 19, 2024, a complaint was filed in the trial court charging

Fails with obstructing official business in violation of R.C. 2921.31(A), and

resisting arrest in violation of R.C. 2921.33(A), both second-degree misdemeanors.

On November 27, 2024, Fails appeared for arraignment and entered pleas of not

guilty.

{¶10} On March 6, 2025, following a motion hearing, the trial court denied

Fails’s motion to suppress after finding that Officer Glanemann had probable cause

to initiate the traffic stop.

{¶11} The case proceeded to a two-day jury trial on April 17, 2025. On April

18, 2025, the jury found Fails guilty of obstructing official business and resisting

arrest. The trial court sentenced Fails to 90 days incarceration, with 75 days

suspended on the condition of a one-year term of probation.

-4- Case No. 1-25-23

{¶12} Fails filed a notice of appeal on April 24, 2025, raising five

assignments of error for our review. For ease of discussion, we will address the

first, second, third, and fourth assignments of error together.

First Assignment of Error

Appellant’s rights to due process under the state and federal constitutions were violated by a conviction for obstruction of official business that was not supported by sufficient evidence.

Second Assignment of Error

Appellant’s conviction for obstruction of official business was not supported by the weight of the evidence.

Third Assignment of Error

Appellant’s due process rights under the state and federal constitutions were violated by a conviction for resisting arrest that was not supported by sufficient evidence.

Fourth Assignment of Error

Appellant’s conviction for resisting arrest was not supported by the weight of the evidence.

{¶13} In his first, second, third, and fourth assignments of error, Fails argues

that his obstructing-official-business and resisting-arrest convictions are based on

insufficient evidence and are against the manifest weight of the evidence.

Standard of Review

{¶14} Manifest “weight of the evidence and sufficiency of the evidence are

clearly different legal concepts.” State v. Thompkins, 78 Ohio St.3d 380, 389

(1997). Thus, we address each legal concept separately.

-5- Case No. 1-25-23

{¶15} “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 (1981), paragraph two of the syllabus, superseded by state constitutional

amendment on other grounds as stated in State v. Smith, 80 Ohio St.3d 89, 102

(1997), fn. 4. Accordingly, “[t]he 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.”

Jenks, 61 Ohio St.3d at paragraph two of the syllabus. “In deciding if the evidence

was sufficient, we neither resolve evidentiary conflicts nor assess the credibility of

witnesses, as both are functions reserved for the trier of fact.” State v. Jones, 2013-

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2026 Ohio 1107, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-fails-ohioctapp-2026.