State v. Ellis

Citations

• 152 N.E.3d 1255
• 2020 Ohio 1115

Syllabus

Obstructing official business R.C. 2921.31(A) fingerprinting sufficiency of evidence having a weapon under disability R.C. 2923.13(A) constructive possession self-representation. - Defendant's conviction for obstructing official business in violation of R.C. 2921.31(A) was not supported by sufficient evidence where defendant's refusal to submit to fingerprinting was not an affirmative act that hindered the police investigation defendant's conviction for having a weapon under disability in violation of R.C. 2923.13(A) was not supported by sufficient evidence where the state conceded defendant never touched or used the gun and failed to produce evidence that he constructively possessed the gun trial court erred in denying defendant's request to represent himself at trial even though the motion was made on the day of trial because the motion was made in response to the trial court's earlier inappropriate attempts to pressure defendant to plead guilty, leading defendant to conclude he could not get a fair trial, and trial counsel offered no objection to the trial court's comments.