State v. Bailey, 2017 Ohio 771

On March 22, 2015, Dennison officers activated emergency lights to stop a green Subaru after hearing a loud exhaust; officers did not initially use siren.
The Subaru failed to fully stop at intersections, drove with tires in the wrong lane, and accelerated through residential streets and a school/park area after midnight.
During a ~9-minute pursuit the Subaru passed multiple oncoming vehicles, once at ~60 mph and later passed a box truck at ~80 mph, then disappeared down a dirt road; no collisions or injuries occurred.
Police later identified Arthur Bailey as the likely driver; Bailey was arrested April 7, 2015, and wrote a statement saying he fled because he was nervous.
A jury convicted Bailey of Failure to Comply with an Order or Signal of a Police Officer (R.C. 2921.331(B)), and found his driving caused a “substantial risk of serious physical harm,” elevating the offense to third-degree felony.
The trial court sentenced Bailey to 36 months’ imprisonment; Bailey appealed arguing insufficient evidence and that the verdict was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Bailey’s driving caused a "substantial risk" of serious physical harm under R.C. 2921.331(B)	State: High-speed maneuvers in residential area, running stop signs, passing oncoming vehicles and a box truck created a strong possibility of serious harm	Bailey: No collisions, no pedestrians or property damage, and pursuit began over a non-felony loud exhaust — insufficient to prove substantial risk	Sufficient: viewing evidence in prosecution's favor, a rational jury could find substantial risk beyond a reasonable doubt
Whether the conviction is against the manifest weight of the evidence	State: Credible testimony and video supported jury's finding; circumstantial evidence is probative	Bailey: Jury lost its way given absence of actual harm and limited indicia of danger	Not against manifest weight: appellate court will not reweigh; jury did not clearly lose its way

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review)
McDaniel v. Brown, 558 U.S. 120 (reaffirming Jackson sufficiency standard)
State v. Thompkins, 78 Ohio St.3d 380 (explains manifest-weight standard and appellate role as "thirteenth juror")
Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (presumption in favor of trial court findings when reviewing weight)
State v. Jenks, 61 Ohio St.3d 259 (circumstantial evidence has same probative value as direct evidence)
Eastley v. Volkman, 132 Ohio St.3d 328 (requirement to give every reasonable presumption in favor of the verdict when reviewing weight)