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State v. Campbell
958 N.E.2d 622
Ohio Ct. App.
2011
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Background

  • Defendant DeWitt Campbell was convicted after a bench trial of inducing panic under R.C. 2917.31.
  • The trial transcript shows a domestic-violence call to Campbell’s apartment, with Campbell delaying entry and making a threatening remark.
  • Officers responded with eight additional officers; a 9-1-1 call reported no visible violence or weapon inside.
  • Campbell was arrested when the door was opened for police after a prolonged standoff; no gun or domestic-violence evidence was found.
  • Campbell testified the initial 9-1-1 call was part of a custody dispute tactic and that his remark referred to a 9-1-1 operator; no other witnesses corroborated violence.
  • The trial court sentenced Campbell to 180 days, and on appeal the conviction was reversed with discharge.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the evidence shows a serious public inconvenience State argues the 8 officers and delayed entry created a serious public inconvenience. Campbell contends there was no proven threat or public inconvenience; officers acted in official capacity. Insufficient evidence; no serious public inconvenience shown.

Key Cases Cited

  • State v. Waddy, 63 Ohio St.3d 424 (1992) (sufficiency review; criminal elements met beyond reasonable doubt)
  • State v. Willard, 144 Ohio App.3d 767 (2001) (sufficiency and evidentiary standard considerations)
  • State v. Isham, 2002-Ohio-5815 (2002) (limits on proving inducing-panic with respect to official duties)
Read the full case

Case Details

Case Name: State v. Campbell
Court Name: Ohio Court of Appeals
Date Published: Jul 15, 2011
Citation: 958 N.E.2d 622
Docket Number: C-100427
Court Abbreviation: Ohio Ct. App.