State v. Harris

Citations

• 2025 Ohio 444

Syllabus

OBSTRUCTING OFFICIAL BUSINESS — RESISTING ARREST — SUFFICIENCY AND WEIGHT OF THE EVIDENCE — R.C. 2945.10 — JURY — RIGHT TO BE PRESENT: Where officers had a reasonable suspicion under the totality of the circumstances that defendant may have been armed and were justified in attempting to conduct a limited pat-down search of defendant, and where defendant's resistance to that search was not privileged, defendant's conviction for obstructing official business was supported by the sufficiency and weight of the evidence. Where officers had a reasonable belief that defendant committed the offense of obstructing official business, and where defendant struggled with the officers when they attempted to arrest him for that offense, defendant's conviction for resisting arrest was supported by the sufficiency and weight of the evidence. Where defendant failed to establish that he suffered material prejudice or that the outcome of the proceedings would have been different, the trial court's delay in instructing the jury after closing arguments in violation of R.C. 2945.10 was not reversible error. Where the record does not affirmatively demonstrate that the trial court communicated with the jury outside of defendant's presence, defendant's right to be present at all stages of the proceedings was not violated.