State v. Walker

Citations

• 2025 Ohio 2982

Syllabus

R.C. 2921.13 – OBSTRUCTING OFFICIAL BUSINESS – SUFFICIENCY – MANIFEST WEIGHT – PURPOSE – SUBSTANTIAL STOPPAGE : The trial court's finding that defendant acted with a purpose to prevent, obstruct, or delay the officers in the performance of their duties within the meaning of the obstructing-official-business statute was supported by sufficient evidence where the State's evidence showed that uniformed police officers had been waiting to warn and cite defendant at the home of his ex-girlfriend, but that defendant, upon meeting the officers' eyes in a well-lit hallway, fled, despite the officers' commands to halt. The trial court's finding that defendant acted with purpose to prevent, obstruct, or delay the officers in the performance of their duties within the meaning of the obstructing-official-business statute was not against the manifest weight of the evidence, because circumstantial evidence of specific intent was not manifestly outweighed by the evidence that the officers never stated they were police and that defendant sat down and complied upon seeing additional officers in his path after a 40-second flight. The trial court's finding that defendant hampered or impeded the officers in the performance of their duties within the meaning of the obstructing-official-business statute was supported by sufficient evidence and was not against the manifest weight of the evidence where officers had been waiting outside the apartment of defendant's former partner in order to cite defendant on an outstanding warrant and warn him to stay away, and where they were delayed in doing so by defendant's 40-second flight through a hallway, down multiple flights of stairs, around the apartment building, and over a fence.