State v. Wilburn

2025 Ohio 4312
CourtOhio Court of Appeals
DecidedSeptember 15, 2025
DocketCA2025-01-009
StatusPublished

This text of 2025 Ohio 4312 (State v. Wilburn) 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. Wilburn, 2025 Ohio 4312 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Wilburn, 2025-Ohio-4312.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

BUTLER COUNTY

STATE OF OHIO, :

Appellee, : CASE NO. CA2025-01-009

: OPINION AND - vs - JUDGMENT ENTRY : 9/15/2025

JORY A. WILBURN, :

Appellant. :

CRIMINAL APPEAL FROM HAMILTON MUNICIPAL COURT Case No. CRB2406439

City of Hamilton Law Department, and Brian K. Harrison, for appellee.

Engel & Martin, LLC, and Joshua A. Engel, for appellant.

____________ OPINION

M. POWELL, J.

{¶ 1} Appellant, Jory Wilburn, appeals his conviction in the Hamilton Municipal

Court for failure to comply with an order or signal of a police officer.

{¶ 2} In the early hours of March 20, 2024, Hamilton Police Officers Dan Pratt Butler CA2025-01-009

and James Tommer separately responded to a "shots fired call" near a bar. The officers

were in uniform, were driving marked police cars, and were invested with the authority to

direct, control, and regulate traffic. Witnesses at the scene directed the officers to

appellant who was found seated in the driver's seat of a vehicle with the engine running.

As the officers approached the vehicle, appellant rolled down his window. Officer Pratt

immediately noticed a strong odor of alcoholic beverage coming from inside the vehicle

and observed that appellant had bloodshot glassy eyes, slurred speech, and extremely

slow movements. Appellant refused to provide his name or identification and told the

officer he did not have a driver's license. Suspecting an OVI, Officer Pratt asked appellant

to exit the vehicle three times. Each time, appellant did not comply. Appellant eventually

exited the vehicle when Officer Pratt opened the driver's door.

{¶ 3} Officer Tommer patted down appellant next to the vehicle. While doing so,

the officer smelled an odor of alcoholic beverage on appellant's breath. Officer Tommer

repeatedly directed appellant to sit in the back of a cruiser, and appellant repeatedly failed

to comply with the officer's directives. Appellant was arrested and handcuffed for refusing

to comply. A struggle ensued requiring officers to physically place appellant in the cruiser.

Due to appellant's combative attitude, field sobriety tests were not administered at the

scene, and appellant subsequently refused to submit to a breathalyzer test at the police

station.

{¶ 4} As a result of the incident, appellant was charged with failure to comply with

an order or signal of a police officer in violation of R.C. 2921.331(A), and OVI. The matter

proceeded to a jury trial on December 16, 2024. Both officers testified on behalf of the

State. At the close of the State's case-in-chief, appellant moved for a judgment of acquittal

under Crim.R. 29(A), which was denied by the trial court. The jury found appellant guilty

of failure to comply but acquitted him of OVI.

-2- Butler CA2025-01-009

{¶ 5} Appellant now appeals, raising one assignment of error:

THERE WAS INSUFFICIENT EVIDENCE TO SUPPORT A CONVICTION FOR FAILURE TO COMPLY.

{¶ 6} Appellant argues that his conviction for failure to comply with an order of a

police officer was not supported by sufficient evidence because he did not disobey an

order relating to the control and regulation of traffic. Thus, appellant does not argue that

the evidence of his failure to comply with the officers' orders was insufficient, but that R.C.

2921.331(A) does not proscribe noncompliance with a police officer's orders unrelated to

the control and regulation of traffic. In this sense, appellant raises a purely legal issue of

statutory interpretation.

{¶ 7} Appellant was convicted of violating R.C. 2921.331(A)—failure to comply

with a police officer's order—which provides, "No person shall fail to comply with any

lawful order or direction of any police officer invested with authority to direct, control, or

regulate traffic." What the General Assembly meant when it used the phrase "authority to

direct, control, or regulate traffic" in drafting the statute has been the subject of some

debate in the courts of appeals. In support of his argument, appellant cites State v. Redd,

2004-Ohio-4689 (2d Dist.).

{¶ 8} Redd involved a motorist who sat in his vehicle in an open parking lot while

he observed a police officer arrest a friend of his for suspicion of OVI. When the motorist

refused to leave the parking lot at the officer's direction, the officer charged him with

violating R.C. 2921.331(A). The Second District Court of Appeals found that the motorist

was not engaged in any activity that constituted a traffic violation, i.e., "any conduct that

implicated the direction, control, or regulation of traffic subject to the officer's lawful

authority," and reversed the motorist's conviction. Id. at ¶ 14. In so finding, the court of

appeals construed R.C. 2921.331(A) as prohibiting the failure to comply with the lawful

-3- Butler CA2025-01-009

order of a police officer relating to the direction, control, or regulation of traffic. Id. at ¶ 12.

Explaining further, the court held that

the "lawful order" of a police officer that R.C. 2921.331(A) contemplates, and with which an offender fails to comply in order for a violation to occur, is one that involves the offender's act or omission in operating a motor vehicle which, by law, an officer is charged with authority to direct, control, or regulate. The manner of that operation need not be unlawful. It is only necessary that the officer be charged by law with authority to direct it and that the offender fails to comply with the officer's particular direction.

Id. at ¶ 19. See also State v. Armstrong-Carter, 2021-Ohio-1110 (2d Dist.); State v.

Adams, 2011-Ohio-4008 (2d Dist.).

{¶ 9} The Ninth District Court of Appeals presented a different take on the statute

in State v. Wagenknecht, 1994 Ohio App. LEXIS 2962, *4 (9th Dist. June 29, 1994). In

that case, a police officer initiated a traffic stop for a speeding violation. The officer

ordered the motorist to remain at the scene to receive a citation but the motorist started

to walk away. In appealing her conviction under R.C. 2921.331(A), the motorist argued

that there must be a direct relationship between the order given and traffic regulation. In

upholding the conviction, the court of appeals held that

Failure to comply does not require . . . that the order given directly relate to traffic matters. The plain meaning of the statute is that a person is guilty of failure to comply, if, after receiving a lawful order from a police officer invested with authority to direct, control, or regulate traffic, that person failed to comply with that order. The police officer's authority must derive from traffic regulation.

Id. at *4. See also State v. Harris, 2025-Ohio-2796 (1st Dist.); State v. Davis, 2001 Ohio

App. LEXIS 1364 (4th Dist.).

{¶ 10} The difference between Redd and Wagenknecht is that Redd interprets

R.C. 2921.331(A) as requiring the officer's lawful order to relate to the direction, control,

or regulation of traffic, whereas Wagenknecht holds that a lawful order relating to any -4- Butler CA2025-01-009

matter is encompassed by the statute as long as the officer's order derives from the

officer's authority to regulate traffic. Thus, under both Redd and Wagenknecht, the police

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Related

State v. Adams
2011 Ohio 4008 (Ohio Court of Appeals, 2011)
State v. Thigpen
2016 Ohio 1374 (Ohio Court of Appeals, 2016)
State v. Redd, Unpublished Decision (9-3-2004)
2004 Ohio 4689 (Ohio Court of Appeals, 2004)
State v. Armstrong-Carter
2021 Ohio 1110 (Ohio Court of Appeals, 2021)
State v. Jenks
574 N.E.2d 492 (Ohio Supreme Court, 1991)
State v. Baker
2023 Ohio 1699 (Ohio Court of Appeals, 2023)
State v. Redden
2024 Ohio 1088 (Ohio Court of Appeals, 2024)
State v. Rodriguez
2024 Ohio 5632 (Ohio Court of Appeals, 2024)
State v. Geter
2025 Ohio 2100 (Ohio Court of Appeals, 2025)
State v. Moore
2025 Ohio 2623 (Ohio Court of Appeals, 2025)
State v. Harris
2025 Ohio 2796 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 4312, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-wilburn-ohioctapp-2025.