Bedford Hts. v. Davis

Citations

• 239 N.E.3d 1145
• 2024 Ohio 1281

Syllabus

Traffic stop obstructing official business overt act insufficient evidence. Appellant was convicted of obstructing official business based on the officer's testimony that he refused to identify himself or provide his driver's license during a traffic stop. However, one cannot be guilty of obstructing official business by doing nothing because the text of R.C. 2921.31, which defines the offense of obstructing official business, specifically requires an offender to act. The mere refusal to answer a police officer's questions regarding one's identity cannot support a conviction for obstructing official business. Because the limited testimony elicited from the officer by the prosecutor did not reflect that appellant engaged in an overt act, appellant's conviction of obstructing official business is vacated for insufficient evidence.