State v. Bryant (Slip Opinion), 2020 Ohio 1041

Late-night collision: Michael Bryant’s car struck Elanor Everhardt’s vehicle; both pulled into a parking lot.
Bryant and Everhardt spoke for about an hour; Bryant smelled of alcohol and made incriminating statements.
Bryant provided his name, phone number, allowed Everhardt to photograph his state ID, and Everhardt photographed his license plate; she did not call police during their conversation but called after leaving her car to summon a tow and then the police.
Bryant left the scene before police arrived; Officer Weston Voss later responded and charged Bryant with, among other offenses, leaving the scene in violation of R.C. 4549.02(A)(1).
Trial court convicted Bryant of leaving the scene; the First District affirmed on the ground Bryant failed to give the required information to the responding police officer. The Ohio Supreme Court accepted review.

Issue	State's Argument	Bryant's Argument	Held
Whether R.C. 4549.02(A)(1) requires a driver who has given required information to other involved persons to remain at the scene until a police officer arrives when no officer is yet present and the driver lacks knowledge police were or will be summoned	The statute requires giving the information to a police officer who responds within a reasonable time; driver must remain for officer who will arrive	No duty to wait for police absent actual knowledge they were called or would be called; providing info to the other involved persons suffices	The Court held the statute does not require the driver to remain for a police officer in those circumstances: if the driver gave the required information to the persons in (a) and (b) and was unaware police had been or would be summoned, leaving does not violate R.C. 4549.02(A)(1)
Meaning of "registered number" under R.C. 4549.02(A)(1)	State: means a separate registration number assigned in the registration process (distinct from license-plate number)	Bryant: means the vehicle’s license-plate number	The Court held "registered number" means the vehicle’s license-plate number; photographing the plate satisfied the requirement

State v. Pariag, 137 Ohio St.3d 81 (2013) (statutory-construction principle: ascertain legislature's intent from text)
State v. Chappell, 127 Ohio St.3d 376 (2010) (apply plain meaning when statute unambiguous)
In re Estate of Centorbi, 129 Ohio St.3d 78 (2011) (give effect to plain statutory language)
State v. Hughes, 86 Ohio St.3d 424 (1999) (court may not add or delete words in statute)
State ex rel. Natl. Lime & Stone Co. v. Marion Cty. Bd. of Commrs., 152 Ohio St.3d 393 (2017) (interpret statute as whole; avoid rendering any provision meaningless)
United Tel. Co. of Ohio v. Limbach, 71 Ohio St.3d 369 (1994) (in pari materia rule: read related statutes together)
Cheap Escape Co., Inc. v. Haddox, L.L.C., 120 Ohio St.3d 493 (2008) (use additional tools to resolve statutory ambiguity)