State v. Brown, 2023 Ohio 2885

Lieutenant Schofield parked an undercover car near an apartment building for surveillance; Daquan Brown and another man entered the building and Brown later exited wearing a mask and hat.
Brown approached Schofield’s car with his phone; Schofield identified himself as a police officer and radioed for backup.
Officer Pitts ran Brown’s name, discovered an active traffic-warrant, and, after Brown lowered his mask, officers identified him and announced an arrest.
Body‑worn camera and officer testimony showed Brown stepping back, pulling his arms away, asking “This is what y’all do for a traffic warrant?” and requiring two officers to escort him to a cruiser; officers reported using more force than usual to position his hands for handcuffs.
Brown was charged with resisting arrest (R.C. 2921.33) and obstructing official business (R.C. 2921.31); a bench trial resulted in conviction for resisting arrest and acquittal on obstruction.
On appeal Brown challenged sufficiency and manifest weight of the evidence; the appellate court affirmed, crediting the officers’ testimony and the video evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved resisting arrest under R.C. 2921.33(A) (force or interference)	Officers and body‑cam showed Brown pulled arms away, stepped back, required extra force and two officers to escort him, and vocalized awareness of the arrest.	Brown claimed confusion (officers initially said he was not detained), denied resisting, and argued only officers testified to force.	Court held evidence sufficient: Brown resisted by pulling away and failing to comply; credited officers.
Whether conviction was against the manifest weight of the evidence	Testimony and video were credible and consistent with resisting conduct; trier of fact properly credited officers.	Brown argued the trial court should not credit officer testimony over his and that the conviction was a miscarriage of justice.	Court found the conviction was not against the manifest weight; it did not clearly lose its way and deferential review governs witness credibility.

State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (Ohio 1997) (standard for manifest‑weight review and reversal only when the factfinder clearly lost its way)
State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (Ohio Ct. App. 1983) (articulating the manifest‑miscarriage standard cited in Thompkins)
State v. Walker, 150 Ohio St.3d 409, 82 N.E.3d 1124 (Ohio 2016) (sufficiency review framed as whether any rational trier of fact could find essential elements proven beyond a reasonable doubt)
State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (Ohio 1991) (governs the standard for sufficiency of the evidence)
State v. Shabazz, 146 Ohio St.3d 404, 57 N.E.3d 1119 (Ohio 2016) (defers to factfinder on credibility when evidence conflicts)
State v. Ellison, 178 Ohio App.3d 734, 900 N.E.2d 228 (Ohio Ct. App. 2008) (discusses de novo review for sufficiency issues)