State v. Nodal

2024 Ohio 2473
CourtOhio Court of Appeals
DecidedJune 28, 2024
Docket22CA011862
StatusPublished

This text of 2024 Ohio 2473 (State v. Nodal) 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. Nodal, 2024 Ohio 2473 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Nodal, 2024-Ohio-2473.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

STATE OF OHIO C.A. No. 22CA011862

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE REUBEN A. NODAL LORAIN MUNICIPAL COURT COUNTY OF LORAIN, OHIO Appellant CASE No. 20CRB0746

DECISION AND JOURNAL ENTRY

Dated: June 28, 2024

FLAGG LANZINGER, Judge.

{¶1} Defendant-Appellant, Reuben Nodal, appeals from the judgment of the Lorain

Municipal Court. This Court affirms.

I.

{¶2} Nodal’s brother is a combat veteran who suffers from PTSD. When triggered, he

can exhibit paranoia and verbal aggression. One afternoon, Nodal received a frantic call from his

brother. The brother said the police officer who lived next door to him had “called his boys * *

*.” He asked Nodal to come over and pick up his son (i.e., Nodal’s nephew). Nodal immediately

left his home and drove to his brother’s house.

{¶3} Nodal knew his brother and his brother’s next-door neighbors had been involved in

several, recent confrontations. About a month and a half before this incident, Nodal spoke with

the police captain in his brother’s jurisdiction. He alerted the captain that his brother struggled

with PTSD and was having issues with his neighbors. He also alerted the captain that the sight of 2

uniformed officers could escalate any PTSD-related symptoms his brother might be experiencing.

In response to Nodal’s call, the captain emailed the members of his department. He shared Nodal’s

concerns. He also shared Nodal’s request that, if possible, he be phoned to assist with any issues

that might arise with his brother.

{¶4} When Nodal arrived at his brother’s house, two officers were already on scene.

Those two officers were speaking with the next-door neighbors. Nodal went inside his brother’s

house and spent between thirty and forty-five minutes with him. More officers arrived while he

was inside the house. During that same time, Nodal exchanged numerous text messages with an

officer on scene. The officer learned that the brother possessed firearms and had a two year old

inside the house. The officer repeatedly told Nodal the police needed to speak with his brother

outside, but Nodal did not want his brother to leave the house. He suggested alternative forms of

electronic communication that would allow his brother to remain inside. The officer stressed that

the brother needed to come outside.

{¶5} Unbeknownst to Nodal, the police had already authorized charges against his

brother. The officer who was communicating with Nodal did not share that information due to

safety concerns. When she reiterated that the police just wanted to talk to the brother, Nodal agreed

to come outside. He opened the door to the house and came outside alone.

{¶6} Nodal advanced to the driveway to speak with a lieutenant on scene. He quickly

observed officers crouched nearby the house, however, and began yelling at them. His brother

then emerged from the house. According to Nodal, the police charged in to secure his brother and,

in doing so, they shoved him and put their hands on him. According to multiple officers on scene,

Nodal tried ushering his brother back inside and used his body as a barrier to prevent them from

gaining entry. The police quickly secured the brother without incident, but Nodal began screaming 3

and flailing. Several officers attempted to escort him outside as he fought against them. When

the officers began losing their grip on Nodal, a third officer used the dry stun feature on his taser

to help subdue him.

{¶7} Nodal was charged with obstructing official business and resisting arrest. A jury

found him not guilty of obstructing official business. It found him guilty of resisting arrest. The

trial court sentenced him to thirty days in jail. Nodal received one day of jail-time credit, and the

court suspended the remainder of his sentence. The court ordered him to pay his court costs and

court-appointed attorney fees. It stayed the execution of his sentence for purposes of this appeal.

{¶8} Nodal now appeals from his conviction and raises three assignments of error for

our review. For ease of analysis, we combine his first and second assignments of error.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT FAILED TO INSTRUCT THE JURY TO CONSIDER ALL OF THE ELEMENTS OF RESISTING A WARRANTLESS ARREST AS PRESCRIBED BY THE OHIO JURY INSTRUCTIONS AND PROPOSED BY TRIAL COUNSEL.

ASSIGNMENT OF ERROR II

TRIAL COUNSEL WAS INEFFECTIVE BY FAILING TO OBJECT TO THE TRIAL COURT’S JURY INSTRUCTIONS OMITTING KEY ELEMENTS OF RESISTING A LAWFUL WARRANTLESS ARREST.

{¶9} In his first assignment of error, Nodal argues the trial court erred when it failed to

instruct the jury on all the elements of resisting arrest. In his second assignment of error, he argues

he received ineffective assistance of counsel because his attorney did not object when the trial

court failed to properly instruct the jury. For the following reasons, we reject his arguments.

{¶10} A person commits the crime of resisting arrest if he, “recklessly or by force, []

resist[s] or interfere[s] with a lawful arrest of the person or another.” R.C. 2921.33(A). “A lawful 4

arrest is an essential element of the crime of resisting arrest.” State v. Vactor, 9th Dist. Lorain No.

02CA008068, 2003-Ohio-7195, ¶ 34. “‘An arrest is ‘lawful’ if the surrounding circumstances

would give a reasonable police officer cause to believe that an offense has been or is being

committed.’” State v. Wigle, 9th Dist. Summit No. 25593, 2011-Ohio-6239, ¶ 11, quoting State v.

Sansalone, 71 Ohio App.3d 284, 285-286 (1st Dist.1991). “The state need not prove that the

defendant was in fact guilty of the offense for which the arrest was based when proving the element

of lawful arrest.” Vactor at ¶ 34.

{¶11} When instructing the jury on resisting arrest, the trial court stated the following:

The defendant[] also been charged with the allegation of resisting arrest. Again, this alleges that on or about the 25th day of July, 2020, in the city and county of Lorain, Ohio, the defendant, Reuban Nodal, recklessly or by force resisted or interfered with the lawful arrest of himself.

“Force” means any violence, compulsion, or constraint physically incurred by any means upon any person or any thing.

“Resist or interfere” means to oppose, obstruct, hinder, impede, interrupt, or prevent an arrest by a law enforcement officer by the use of force or recklessly by any means, such as going limp, or any other passive or indirect conduct.

“Arrest” means any intent to arrest; under real or pretended authority; accompanied by actual constructive seizure or detention of that person; and which is so understood by that person being arrested.

“Lawful arrest” means you must decide whether the arrest was, in fact, lawful.

“Warrantless arrest.” An arrest is lawful if the offense for which the arrest was being made was one for which a defendant could be arrested.

Nodal did not object to the trial court’s instructions.

{¶12} Nodal argues the trial court erred when it instructed the jury on the lawful arrest

element of resisting arrest. That is because the trial court did not tell the jury that an arrest is lawful

if, under the surrounding circumstances, a reasonable police officer could have believed an offense

had been or was being committed. Nodal argues his arrest was unlawful because no reasonable 5

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Neder v. United States
527 U.S. 1 (Supreme Court, 1999)
State v. Wigle
2011 Ohio 6239 (Ohio Court of Appeals, 2011)
State v. Vactor, Unpublished Decision (12-31-2003)
2003 Ohio 7195 (Ohio Court of Appeals, 2003)
State v. Sansalone
593 N.E.2d 390 (Ohio Court of Appeals, 1991)
State v. Sowell (Slip Opinion)
2016 Ohio 8025 (Ohio Supreme Court, 2016)
State v. Meinke
2017 Ohio 7787 (Ohio Court of Appeals, 2017)
State v. Fry
2017 Ohio 9077 (Ohio Court of Appeals, 2017)
State v. Singh
2018 Ohio 3473 (Ohio Court of Appeals, 2018)
Akron v. Sage
2018 Ohio 3662 (Ohio Court of Appeals, 2018)
State v. Claren
2020 Ohio 615 (Ohio Court of Appeals, 2020)
State v. Bradley
538 N.E.2d 373 (Ohio Supreme Court, 1989)
State v. Wolons
541 N.E.2d 443 (Ohio Supreme Court, 1989)

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Bluebook (online)
2024 Ohio 2473, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-nodal-ohioctapp-2024.