State v. Maynard

Summary

The Ohio Fifth District Court of Appeals affirmed Dana L. Maynard’s convictions for operating a vehicle under the influence of alcohol and obstructing official business. The court held that circumstantial evidence sufficiently established vehicle operation while intoxicated and that Maynard’s resistance to a court-authorized blood draw impeded official duties; the State’s cross-appeal concerning severance and exclusion of blood-test results was dismissed as moot.

Holdings

1. The State presented sufficient evidence for a rational trier of fact to find beyond a reasonable doubt that Maynard operated the vehicle while under the influence of alcohol.
2. The State presented sufficient evidence that Maynard, without privilege and with the requisite purpose, actually interfered with and made more difficult the execution of a lawful blood-draw warrant, thereby obstructing official business under R.C. 2921.31(A).
3. The State's cross-appeal concerning severance of the OVI counts and exclusion of the blood-test results was moot because no ruling could provide the State a more favorable outcome after Maynard's convictions were affirmed.

Questions Presented

1. Whether sufficient evidence supported Maynard's conviction for operating a vehicle under the influence of alcohol under R.C. 4511.19(A)(1)(a), including evidence that he operated the vehicle while under the influence.
2. Whether sufficient evidence supported Maynard's conviction for obstructing official business under R.C. 2921.31(A), including evidence that his conduct actually hampered or impeded officials executing a blood-draw warrant.
3. Whether the State's cross-appeal challenging severance of the OVI counts and exclusion of the blood-test results presented a live controversy after Maynard's convictions were affirmed.

Disposition

affirmed