State v. Coffman

Citations

• 2024 Ohio 1182

Syllabus

OBSTRUCTION OF OFFICIAL BUSINESS – EVIDENCE – PURPOSELY – SUBSTANTIAL STOPPAGE – MOOTNESS: Defendant's obstruction-of-official-business conviction under R.C. 2921.31 was not supported by sufficient evidence because defendant did not create a \substantial stoppage\ in the police officer's investigation where the delay caused by defendant's behavior lasted approximately 20 seconds, and the state provided no evidence of defendant's hampering or impeding the investigation beyond that de minimis delay. [But see DISSENT: The cause is moot because defendant completed the sentence prior to filing the appeal, defendant did not demonstrate anything to indicate he served the sentence involuntarily, and defendant already suffers the collateral disabilities of a misdemeanor conviction for obstruction of official business.]