State v. Blassingame, 2021 Ohio 426

On April 14, 2019, Derrick Blassingame was arrested and initially charged with failing to provide identification and obstructing pedestrian/vehicular traffic; after pretrial events the obstructing charge was reduced to disorderly conduct (R.C. 2917.11(A)(4)).
Blassingame had multiple appointed counsel changes and obtained four prior continuances; his counsel repeatedly requested discovery, specifically the arresting officer’s body‑camera video.
The City responded that the officer’s body‑camera video was beyond the department’s 90‑day retention period and thus unavailable; all other discovery was produced by August 31, 2019.
Blassingame asked for a fifth continuance to hire private counsel and obtain additional discovery; the trial court denied the continuance as dilatory and because the requested video could not be produced.
The prosecution dismissed the identification charge and proceeded to a bench trial on disorderly conduct; the court allowed the public defender to assist Blassingame in self‑representation.
Witnesses (two officers and a dance‑studio volunteer) testified Blassingame was lying across the sidewalk in front of a dance studio, causing children to step into the street to avoid him; Blassingame testified he was sitting cross‑legged and waiting for a ride. The court found the state’s witnesses credible and convicted him; he was fined $100.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying Blassingame’s continuance request to hire private counsel and obtain discovery	Denial proper: defendant already received multiple continuances, discovery had been produced, body‑cam unavailable due to retention policy, and further delay would be dilatory	Needed more time to hire counsel and obtain the body‑camera video; denial prejudiced his defense	No abuse of discretion; continuance denial affirmed
Whether the evidence was sufficient and the verdict against the weight of the evidence	Evidence showed reckless hindering of pedestrian movement (witnesses saw children forced into the street), satisfying R.C. 2917.11(A)(4)	Insufficient/contradictory evidence — defendant was only sitting and no children were actually impeded	Sufficiency and weight upheld; conviction affirmed

State v. Unger, 67 Ohio St.2d 65, 423 N.E.2d 1078 (1981) (abuse‑of‑discretion factors for continuance requests)
State v. Wheeler, 65 N.E.3d 182 (Ohio Ct. App.) (no constitutional right to appointed counsel when prosecution carries no possibility of incarceration)
State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (1997) (distinguishing sufficiency and weight-of-the-evidence standards)