State v. Brantley
2017 Ohio 8810
| Ohio Ct. App. | 2017Background
- Appellant Raheem Brantley was indicted for assault on a peace officer (fourth-degree felony) and resisting arrest (first-degree misdemeanor) after an October 2016 incident at a Brookfield Township grocery involving suspected counterfeit checks.
- Officers detained two women who were attempting to cash bad checks; they then approached a silver car connected to the women. The driver (female) was recognized from an earlier incident, arrested, and placed in a cruiser.
- Brantley sat in the passenger seat; officers told him to exit. He initially complied but refused to provide identifying information and was told he was not free to leave. The car was effectively blocked by police cruisers.
- Brantley ran from the vehicle, slipped, and a struggle followed when Chief Faustino attempted to detain him. Patrolman First testified that Brantley struck Chief Faustino in the face, injuring him; Brantley then fled again and was tasered and arrested.
- Brantley denied pushing or striking the officer and claimed any contact was accidental; the jury convicted him on both counts and the court sentenced him to 18 months’ imprisonment (concurrent sentences).
- On appeal, Brantley challenged sufficiency of evidence for resisting arrest and argued both convictions were against the manifest weight of the evidence; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for resisting arrest | State: evidence showed Brantley resisted while not free to leave and caused physical harm to an officer | Brantley: no sufficient proof he resisted or caused harm; contact was accidental | Court: Sufficient evidence; Crim.R. 29 denial proper |
| Manifest weight of evidence for resisting arrest | State: witness testimony and injuries support conviction | Brantley: officers’ accounts conflicted and were not credible | Court: jury credited state witnesses; verdict not against manifest weight |
| Manifest weight of evidence for assault on a peace officer | State: Brantley knowingly struck officer during detention/arrest | Brantley: denied intentional strike; claimed officers lied | Court: testimony and injury evidence support conviction; not against manifest weight |
| Whether Brantley was "free to leave" / in custody for arrest/resisting analysis | State: car blocked by cruisers and officer statements made clear he was not free to leave | Brantley: claimed he was never told he was under arrest or not free to leave | Court: objective circumstances and officer statement meant he was not free to leave; arrest in process when resistance occurred |
Key Cases Cited
- Bridgeman v. Ohio, 55 Ohio St.2d 261 (establishes sufficiency standard for Crim.R. 29)
- Jenks v. Ohio, 61 Ohio St.3d 259 (evidence viewed in light most favorable to prosecution for sufficiency review)
- Dennis v. Ohio, 79 Ohio St.3d 421 (verdict will not be disturbed unless reasonable minds could not reach it)
- Thompkins v. Ohio, 78 Ohio St.3d 380 (reversal for manifest weight only in exceptional cases)
- DeHass v. Ohio, 10 Ohio St.2d 230 (trier of fact best assesses witness credibility)
- Maurer v. Ohio, 15 Ohio St.3d 239 (magic words not required to constitute an arrest)
- Barker v. Ohio, 53 Ohio St.2d 135 (elements of an arrest: intent, authority, seizure/detention, understood by person)
- Biros v. Ohio, 78 Ohio St.3d 426 (circumstantial and direct evidence have same probative value)