History
  • No items yet
midpage
State v. Cantrell
2021 Ohio 180
Ohio Ct. App.
2021
Read the full case

Background

  • June 23, 2018: Officer Shaun Watson responded to a reported altercation and went to a nearby McDonald’s where he observed a silver Cadillac (driven by Cantrell) in the parking lot.
  • As Watson backed his cruiser, he testified Cantrell sped off; Watson activated lights and siren while Cantrell was still in the lot and pursued him.
  • Cantrell drove the wrong way onto Groveport Road and then northbound in the southbound lanes of Alum Creek Drive, crossed multiple lanes, struck a concrete median, popped a tire, spun out, and nearly struck an ambulance; the chase lasted ~13–16 seconds.
  • Officers smelled alcohol on Cantrell; parties stipulated Cantrell was later convicted of OVI and criminal mischief from the same incident.
  • A jury convicted Cantrell of failure to comply with an order or signal of a police officer under R.C. 2921.331 and found the conduct caused a substantial risk of serious physical harm (felony enhancement). Sentence: two years community control and 36-month license suspension.
  • Cantrell argued on appeal the evidence was legally insufficient and the verdict was against the manifest weight of the evidence because he did not willfully flee or elude the officer.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency: Did the State present enough evidence to prove Cantrell willfully fled after a visible/audible signal? Officer activated lights/siren while Cantrell was still in lot; Cantrell sped off and drove wrong-way at high speed—sufficient for a reasonable juror to find willfulness. Cantrell testified he didn’t hear siren, was confused/unfamiliar with road layout, and did not intentionally flee. Affirmed. Viewing evidence in prosecution’s favor, a rational juror could find willful eluding beyond a reasonable doubt.
Manifest weight: Was the guilty verdict against the manifest weight of the evidence? Witnesses corroborated that lights were on and Cantrell accelerated and engaged in dangerous wrong-way driving, creating substantial risk. Cantrell’s testimony provided an innocent explanation (confusion, intoxication, no intent to flee). Affirmed. Credibility and weight were for the jury; this is not the exceptional case to overturn the verdict.

Key Cases Cited

  • State v. Jenks, 61 Ohio St.3d 259 (1991) (sets standard for sufficiency review — view evidence in light most favorable to prosecution)
  • State v. McDonald, 137 Ohio St.3d 517 (2013) (describes misdemeanor-to-felony gradings and enhancement under R.C. 2921.331)
  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (explains manifest-weight standard and role of appellate court as thirteenth juror)
  • State v. Garrard, 170 Ohio App.3d 487 (2007) (trier of fact may infer defendant was aware of officer’s signal)
  • State v. Semenchuk, 122 Ohio App.3d 30 (1997) (strong possibility of harm can establish requisite mental culpability)
  • State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight of testimony are for the trier of fact)
  • State v. Martin, 20 Ohio App.3d 172 (1983) (appellate reversal for manifest weight permitted only in exceptional cases)
Read the full case

Case Details

Case Name: State v. Cantrell
Court Name: Ohio Court of Appeals
Date Published: Jan 26, 2021
Citation: 2021 Ohio 180
Docket Number: 20AP-27
Court Abbreviation: Ohio Ct. App.