State v. Harris

Citations

• 2023 Ohio 4387

Syllabus

AGGRAVATED MENACING – OBSTRUCTION OF OFFICIAL BUSINESS – SUBSTANTIAL STOPPAGE – CRIMINAL TRESPASS – PURPOSEFUL – BEING IN A PARK AFTER HOURS: Defendant's conviction for aggravated menacing in violation of R.C. 2903.21 was not contrary to the manifest weight of the evidence where the jury watched the body-worn camera video depicting defendant making the threat to a police officer, heard the police officer testify about his belief that defendant would cause serious physical harm, heard defendant testify, and observed both witnesses on the stand. Defendant's conviction for obstruction of official business in violation of R.C. 2921.31 was supported by sufficient evidence and not contrary to the manifest weight of the evidence where defendant created a \substantial stoppage\ in the police officer's investigation sufficient to obstruct official business and the jury could reasonably infer that defendant purposefully caused that substantial stoppage where the police officer told defendant that he would be issued a ticket, defendant responded by walking away from the police officer, necessitating a foot pursuit, and defendant ran when other officers arrived to block defendant's path and defendant was ordered to stop. Defendant's conviction for being in Washington Park after hours in violation of Cincinnati Park Board Rule 21 was supported by sufficient evidence and not contrary to the manifest weight of the evidence where Washington Park was closed between 11:00 p.m. and 6:00 a.m., defendant was in Washington Park at 4:45 a.m., and defendant was in the middle of the park, away from the routes directly connecting the public parking garages to the city streets. Defendant's conviction for criminal trespass in violation of R.C. 2911.21(A)(1) was supported by sufficient evidence and not contrary to the manifest weight of the evidence where defendant was in Washington Park while it was closed, multiple signs communicated the park's open hours, and defendant admitted to knowing wh