State v. Davis

Citations

• 2026 Ohio 2102

Syllabus

OBSTRUCTING OFFICIAL BUSINESS — AFFIRMATIVE ACT — SUBSTANTIAL STOPPAGE — FORFEITED ARGUMENTS — PLAIN ERROR: Defendant's conviction for obstructing official business was supported by sufficient evidence and was not contrary to the manifest weight of the evidence where defendant committed affirmative acts in the form of physically resisting the officers while they were trying to arrest him by pulling away when one officer grabbed his wrist, struggling to stay on his back once on the ground, and keeping one arm pinned beneath him while the officers attempted to apply handcuffs; also, defendant's acts hampered or impeded the officers in the performance of their official duties by delaying the officers' attempts to take defendant into custody and, although the arrest was accomplished in approximately 60 seconds, there is no temporal requirement for substantial stoppage. Where defendant failed to argue before the trial court that the obstructing-official-business statute only applies to an individual who is not under arrest and that the statute requires an illegal act and not just an affirmative act, and where defendant further failed to argue plain error in his appellate brief, defendant forfeited the arguments.