State v. Williams

Summary

The Ohio Eighth District Court of Appeals affirmed Jonathan Williams's conviction for obstructing official business under R.C. 2921.31(A). The court held that evidence that Williams fled from pursuing police officers, despite activated lights and siren, was sufficient to establish an affirmative act intended to impede official duties. The court remanded for a nunc pro tunc sentencing entry correcting inapplicable community-control language.

Holdings

1. The appeal was not moot because Williams did not voluntarily serve his sentence. He contested the charges at trial, received 90 days of jail-time credit against a 90-day sentence, and therefore had no sentence upon which to seek a stay.
2. The evidence was sufficient to establish that Williams knowingly fled from the police with the intent to impede Officer Mitri’s performance of official duties, thereby satisfying R.C. 2921.31(A).
3. The sentencing entry was inaccurate because it included inapplicable community-control and probation language, so the case was remanded for a nunc pro tunc entry as of and for June 1, 2022.

Questions Presented

1. Whether Williams’s appeal was moot because he had completed the sentence imposed for his misdemeanor conviction.
2. Whether the evidence was sufficient to prove obstructing official business under R.C. 2921.31(A).
3. Whether the sentencing entry accurately reflected the sentence imposed in open court and required correction.

Disposition

affirmed