State v. Duncan

Citations

• 2024 Ohio 5290

Syllabus

OVI – SUPPRESSION – WITNESSES – OFFICER TESTIMONY – PROBABLE CAUSE: The trial court did not err when it held that the officers had probable cause to arrest defendant in partially denying her motion to suppress, as the officers had sufficient information that would lead a prudent person to believe that defendant was operating a vehicle while intoxicated. The trial court did not abuse its discretion when it allowed the officers to testify as to their observations of defendant throughout the administration of the field sobriety test, even though the results of the test were inadmissible, because the officers were permitted to testify as to mere observations, as any lay witness could. The trial court's judgment, convicting defendant of OVI, was not against the manifest weight of the evidence nor was there insufficient evidence to support it because even though some evidence weighed in defendant's favor, the evidence did not heavily weigh against the judgment.