State v. Boystel, 2021 Ohio 2529

On Oct. 14, 2020, at the intersection of Church (through street) and Wallace (two-way stop) in Urbana, Boystel stopped at the Wallace stop sign, pulled into the intersection to make a right turn, and struck Faulkner’s westbound vehicle; both cars sustained minor damage.
Officer Keith Hurst investigated at the scene, determined Boystel at fault, and cited her for failing to yield in violation of Urbana Codified Ordinance 331.19(a) (minor misdemeanor).
Boystel pled not guilty; a bench trial was held Dec. 16, 2020. The City called Faulkner and Officer Hurst; Boystel and a passenger (Kaylee Jones) testified for the defense.
The municipal court found Boystel guilty, imposed fines and costs, and assessed two license demerit points; Boystel appealed.
On appeal Boystel raised five assignments of error focusing on mootness/collateral consequences, sufficiency and manifest weight, plain-error/strict construction, and an asserted plea agreement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness / Justiciability of appeal	Conviction moot after payment of fine and costs	Appeal not moot because two demerit points on license are collateral consequences	Not moot: two license points preserved appeal
Sufficiency and manifest weight of the evidence	Evidence (Faulkner, officer) showed Boystel failed to yield after stopping	Faystel (sic) — defendant argued Faulkner driving center, speeding, distracted; Boystel lacked visibility	Conviction supported; verdict not against manifest weight and was sufficient
Plain error / strict construction / mens rea	Ordinance unambiguous; traffic safety supports strict liability enforcement	Trial court should have strictly construed ordinance in defendant’s favor and not treat failure-to-yield as strict liability	No plain error; ordinance unambiguous and traffic offenses may be enforced under strict liability
Alleged plea agreement	No plea agreement was presented to the court on the record	Trial court abused discretion by refusing purported plea agreement	No record evidence of a plea agreement; assignment overruled

Cleveland Hts. v. Lewis, 953 N.E.2d 278 (Ohio 2011) (mootness doctrine when sentence served)
State v. Wilson, 325 N.E.2d 236 (Ohio 1975) (appeal moot absent collateral consequences after sentence/fine paid)
In re S.J.K., 867 N.E.2d 406 (Ohio 2007) (license points are collateral consequences preserving appeal)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (sufficiency/manifest-weight standards)
Eastley v. Volkman, 972 N.E.2d 517 (Ohio 2012) (manifest-weight review framework)
United States v. Morissette, 342 U.S. 246 (U.S. 1952) (traffic/public-safety offenses amenable to strict liability)
State v. Warner, 546 N.E.2d 18 (Ohio 1989) (canon of strict construction not to defeat statutory purpose)
State v. Cleary, 490 N.E.2d 574 (Ohio 1986) (acceptance of strict-liability approach for motor-vehicle offenses)