State v. Wilkerson

2025 Ohio 1279
CourtOhio Court of Appeals
DecidedApril 11, 2025
Docket30196
StatusPublished
Cited by1 cases

This text of 2025 Ohio 1279 (State v. Wilkerson) 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. Wilkerson, 2025 Ohio 1279 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Wilkerson, 2025-Ohio-1279.]

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

STATE OF OHIO : : Appellee : C.A. No. 30196 : v. : Trial Court Case No. 2023 CR 01099 : LAMONT L. WILKERSON : (Criminal Appeal from Common Pleas : Court) Appellant : :

...........

OPINION

Rendered on April 11, 2025

CHIMA R. EKEH, Attorney for Appellant

MATHIAS H. HECK, JR., by SARAH H. CHANEY, Attorney for Appellee

.............

EPLEY, P.J.

{¶ 1} Lamont L. Wilkerson appeals from his convictions in the Montgomery County

Court of Common Pleas for failure to comply and obstructing official business. He claims

that his conviction for failure to comply was based on insufficient evidence, that the trial

court should have granted his Crim.R. 29 motion on obstructing official business, and that -2-

the court failed to consider R.C. 2921.331(C)(5)(b) at sentencing. For the following

reasons, Wilkerson’s conviction for obstructing official business will be vacated. His

conviction for failure to comply will be affirmed.

I. Facts and Procedural History

{¶ 2} During the evening of February 16, 2023, a detective involved in a special

proactive enforcement detail was conducting surveillance at a gas station when a

Mitsubishi SUV caught his attention. After following the vehicle and observing several

traffic violations, the detective instructed a deputy in a marked cruiser to initiate a traffic

stop. When the deputy attempted to do so, the vehicle sped away. The deputy initially

followed, reaching approximately 60 mph in a 35-mph zone, but based on policy

governing the pursuit of fleeing vehicles, he quickly terminated his pursuit. However, the

vehicle was being tracked by a law enforcement helicopter, which relayed the vehicle’s

location to the officers involved in the detail. The pilot tracked the vehicle’s path and

observed the driver park behind a residence and hurry inside.

{¶ 3} Numerous law enforcement officers responded to the residence, surrounded

it, and asked the driver of the vehicle to come out. They attempted to negotiate with the

occupants, but their efforts were initially unsuccessful. Ultimately, Wilkerson came out

of the home and was arrested. While speaking with another deputy, he admitted to being

the driver.

{¶ 4} Three months later, Wilkerson was indicted on failure to comply with an order

or signal of a police officer in violation of R.C. 2921.331(B), a third-degree felony, and

obstructing official business in violation of R.C. 2921.31(A), a second-degree -3-

misdemeanor. He moved to suppress the evidence against him, claiming that the

attempted stop and his subsequent arrest were unlawful and that the statements he made

to police were involuntary and obtained in violation of his Miranda rights. After a hearing,

the trial court overruled the motion. Wilkerson later filed a notice of alibi, claiming that

he was with others at the residence where he was arrested at the time of the pursuit.

{¶ 5} The matter proceeded to a jury trial, during which the State offered the

testimony of four law enforcement officers and related exhibits. Wilkerson presented an

alibi witness. After deliberating, the jury found Wilkerson guilty of both charges. It

further found that Wilkerson’s operation of the motor vehicle had caused a substantial risk

of serious physical harm to persons or property. At sentencing, the trial court imposed

24 months in prison for failure to comply, to be served concurrently with a 90-day

sentence for obstructing official business. The court also suspended Wilkerson’s driver’s

license for ten years and ordered him to pay court costs.

{¶ 6} Wilkerson appeals from his convictions, raising three assignments of error.

We will address them in a manner that facilitates our analysis.

II. Sufficiency and Manifest Weight of the Evidence

{¶ 7} In his first assignment of error, Wilkerson claims that the State failed to

present sufficient evidence that he was the driver of the vehicle to support the charge of

failure to comply. Although couched in terms of sufficiency of the evidence, Wilkerson

relies on the totality of the evidence, including the testimony of his alibi witness, which

implies a manifest-weight argument. We therefore will construe his appellate brief as

challenging his conviction on both grounds. Wilkerson’s third assignment of error claims -4-

that the trial court should have granted his Crim.R. 29(A) motion on obstructing official

business, which also concerns the sufficiency of the evidence. Accordingly, we will

address both assignments of error together.

A. Relevant Legal Standards

{¶ 8} When reviewing the denial of a Crim.R. 29(A) motion, an appellate court

applies the same standard as is used to review a claim based on the sufficiency of the

evidence. State v. Page, 2017-Ohio-568, ¶ 7 (2d Dist.), citing State v. Sheppeard, 2013-

Ohio-812, ¶ 51 (2d Dist.). “A sufficiency of the evidence argument disputes whether the

State has 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 State v. Thompkins, 78 Ohio St.3d 380, 386 (1997). The

relevant inquiry is whether any rational finder of fact, viewing the evidence in a light most

favorable to the State, could have found the essential elements of the crime proven

beyond a reasonable doubt. State v. Dennis, 79 Ohio St.3d 421, 430 (1997). A guilty

verdict will not be disturbed on appeal unless “reasonable minds could not reach the

conclusion reached by the trier-of-fact.” Id.

{¶ 9} In reviewing the trial court’s denial of a Crim.R. 29(A) motion at the end of

the State’s case, we consider only the evidence that had been presented prior to the

motion. State v. Jackson, 2022-Ohio-2805, ¶ 9 (2d Dist.); State v. Powell, 2018-Ohio-

4693, ¶ 22 (2d Dist.), citing Sheppeard at ¶ 51. For Crim.R. 29(A) motions made after

the defense’s evidence, we consider all the evidence admitted at trial. State v. Stone,

2024-Ohio-177, ¶ 9 (2d Dist.). -5-

{¶ 10} In contrast, “[a] weight of the evidence argument challenges the believability

of the evidence and asks which of the competing inferences suggested by the evidence

is more believable or persuasive.” (Citation omitted.) Wilson at ¶ 12; see Eastley v.

Volkman, 2012-Ohio-2179, ¶ 19. When reviewing an argument challenging the weight

of the evidence, an appellate court may not substitute its view for that of the trier of fact.

Rather, we review the entire record, weigh the evidence and all reasonable inferences,

consider the credibility of witnesses, and determine whether, in resolving conflicts in the

evidence, the finder of fact clearly lost its way and created such a manifest miscarriage

of justice that the conviction must be reversed and a new trial ordered. Thompkins at

387, quoting State v. Martin, 20 Ohio App.3d 172, 175 (1st Dist. 1983). A judgment of

conviction should be reversed as being against the manifest weight of the evidence only

in exceptional circumstances. Martin at 175.

{¶ 11} We note that Wilkerson’s appellate brief refers to evidence that was

presented at the hearing on his motion to suppress and information discussed in a sidebar

discussion.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Dorsey
2025 Ohio 2977 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1279, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-wilkerson-ohioctapp-2025.