State v. Held

Citations

• 2026 Ohio 898

Syllabus

OVI — CHEMICAL TEST — REFUSAL — R.C. 4511.19(A)(2) — MOTION TO SUPPRESS — SUFFICIENCY — MANIFEST WEIGHT: In an OVI prosecution, the trial court did not err in denying a motion to dismiss where officer observation that defendant smelled strongly of alcohol, had bloodshot and watery eyes, slurred his speech, was acting strangely, and refused to participate in field sobriety tests supported a finding of probable cause to arrest for OVI. Defendant's conviction for refusing to take a chemical test under R.C. 4511.19(A)(2) was supported by sufficient evidence and was not against the manifest weight of the evidence where the jury considered testimony from the arresting officers that defendant strongly smelled of alcohol, had bloodshot and watery eyes, slurred his speech, acted strangely, and refused to participate in field sobriety testing, and could observe footage from an officer's body-worn camera showing defendant's actions.