State v. Assefa

Citations

• 2023 Ohio 385

Syllabus

OVI – PROBABLE CAUSE – EVIDENCE – MANIFEST WEIGHT – SUFFICIENCY: The trial court properly denied defendant's motion to suppress evidence stemming from a warrantless arrest where the arresting officer had probable cause to believe that defendant was under the influence of alcohol based on defendant's physiological indicia, combative demeanor, colliding with a parked car, and refusal to submit to sobriety testing. Defendant's OVI conviction was based on sufficient evidence and was not against the manifest weight of the evidence where the trial court based its finding of guilt on credible testimony of the arresting officer and body-worn-camera video that supported the conclusion that defendant's driving was appreciably impaired by alcohol.