State v. Betts
2017 Ohio 2824
| Ohio Ct. App. | 2017Background
- At ~2:23 a.m. on June 20, 2016, Trooper Castellanos stopped Clifford Betts for high beams and no front license plate; Betts was the driver of a silver BMW.
- Trooper smelled a moderate odor of alcohol on Betts, observed red/watery eyes, and saw Betts fumble with his keys and registration.
- Trooper administered standardized field sobriety tests (HGN and walk-and-turn); observed HGN clues (total six) and multiple walk-and-turn clues; one-leg stand was not given due to arthritis complaints.
- Betts refused a breath chemical test after arrest and declined to sign the implied-consent (2255) form; Trooper read consequences and witnessed the form.
- At jury trial, State presented Trooper Castellanos; defense called a friend who testified Betts did not drink around her but could not account for his prior activity. Jury convicted Betts of OVI and Display of Plates; conviction affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to convict for OVI | State: evidence (odor, HGN, walk-and-turn, admission of drinking, refusal) supports conviction | Betts: no observed impaired driving; SFSTs compromised by arthritis; procedural irregularities (dashcam/view, rushed 2255) | Affirmed — evidence sufficient for a rational trier of fact to find guilt beyond reasonable doubt |
| Manifest weight of the evidence | State: credibility and objective SFST results support jury verdict | Betts: jury lost its way given medical issues and lack of driving impairment evidence | Affirmed — appellate court defers to jury credibility findings; verdict not against manifest weight |
| Refusal to submit to chemical test | State: Trooper properly advised Betts and requested breath test; Betts refused after being warned | Betts: challenged manner/timing of 2255 form completion and his understanding/signature absence | Affirmed — refusal supported by testimony that advisements were given and Betts declined |
| Admissibility/administration of SFSTs | State: Trooper properly administered HGN and walk-and-turn per NHTSA guidelines | Betts: tests were affected by medical condition and not fully documented (dashcam) | Affirmed — trial credited trooper’s administration and observations; medical complaints did not invalidate results |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (1991) (standard for reviewing sufficiency of the evidence)
- State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (1997) (standard for reviewing manifest weight of the evidence)
- State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (1984) (articulates manifest-weight review as appellate court acting as thirteenth juror)
- State v. Carter, 72 Ohio St.3d 545, 651 N.E.2d 965 (1995) (discusses appellate review of motions for acquittal)