State v. Carter, 2022 Ohio 3901

Defendant Savoz Carter was charged with resisting arrest under R.C. 2921.33(A) after police found him associated with a vehicle identified as stolen and learned he had outstanding warrants.
Officer Dawson ran the VIN, saw Carter’s photo on his computer, requested backup and a tow, and waited for another officer before effecting the arrest.
Dawson ordered Carter to lie face down with hands behind his back; Carter knelt but refused to lie prone or place his hands behind his back, repeatedly asked why he was being arrested, moved, raised an arm, and lifted his body off the ground.
Dawson deployed his Taser twice—first when Carter put his hand on the ground and began to push up, and again when Carter appeared to reach toward his pocket/waistband—after which a second officer arrived and handcuffed Carter.
At trial Carter testified he owned the car, didn’t know it was reported stolen, was unaware of warrants, and refused to lie face down because he didn’t trust the officer; the bench found him guilty.
Carter appealed, arguing the conviction was not supported by sufficient evidence and was against the manifest weight of the evidence; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence was sufficient and the conviction not against the manifest weight for resisting arrest (recklessly resisting a lawful arrest)	Carter repeatedly refused commands, moved, raised his arm, and lifted his body despite orders—conduct showing heedless indifference and reckless interference with a lawful arrest	Carter was calm and confused, did not meaningfully resist—he merely knelt and refused to lie face down out of distrust; conviction unsupported/against manifest weight	Court held the evidence sufficient and weight of evidence supported conviction; judgment affirmed

State v. Jenks, 61 Ohio St.3d 259 (1991) (sets Ohio sufficiency-of-evidence standard)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (explains manifest-weight review and deference to factfinder)