State v. Bryant, 2018 Ohio 3756

On March 16, 2017, Michael Bryant collided with Elanor Everhardt’s car; both pulled into a parking lot and spoke for about an hour.
Everhardt testified Bryant smelled of alcohol, admitted he’d been drinking, told her he had no license/insurance/registration, gave his name and phone number, and allowed her to photograph his non-driver ID and license plate.
Bryant asked Everhardt not to call the police; she did not agree to that request and later (after Bryant left) called a tow truck and then the police.
When police arrived, Bryant was gone; the officer testified Everhardt did not have the vehicle’s registration number.
Bryant was convicted after a bench trial of failure to control his vehicle (not appealed) and failure to stop after an accident under R.C. 4549.02; he was acquitted of driving under an FRA suspension.
The court addressed whether Bryant’s leaving violated the amended statute’s requirement to give name/address and the registered number to the police officer at the scene.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient/weight supported conviction for failure to stop after an accident under R.C. 4549.02	Bryant failed to provide required information to the police officer at the scene because he left before officer arrival	No police officer was at the scene while Bryant was present; statute requires giving info to an officer "at the scene," so leaving before officer arrival does not violate statute	Conviction affirmed: under these facts Bryant had duty to provide information to the officer when officer arrived and failed to do so, supporting conviction
Whether photographing the license plate satisfied the statute’s requirement to give the vehicle’s "registered number"	Plaintiff argued Bryant’s conduct (providing plate photo, name, phone) did not satisfy statutory duty to provide required information to officer	Defendant argued plate photo and other provided info sufficed and/or statute did not require remaining until an officer arrived	Court did not decide whether plate number equals "registered number"; held regardless Bryant was required to give information to officer and failed to do so, so conviction stands

Jenks v. Ohio, 61 Ohio St.3d 259 (standard for sufficiency review)
Thompkins v. Ohio, 78 Ohio St.3d 380 (standard for manifest-weight review)
State v. Harris, 92 N.E.3d 1283 (appellate-rule requirement to raise assignments of error)
State v. Kreischer, 109 Ohio St.3d 391 (court applies unambiguous statutory text as written)
State v. Straley, 139 Ohio St.3d 339 (ambiguities construed in defendant's favor when applicable)
State v. Vaduva, 66 N.E.3d 212 (rule on statutory interpretation favoring defendant when ambiguous)