State v. Craver, 2020 Ohio 5407

On May 13, 2019, Detective Sam Humphrey, conducting surveillance in an unmarked car, observed a gray Dodge Challenger; through binoculars he identified the driver as Angelo Craver, a man he had known from prior contacts and whom he believed did not have a valid license.
Humphrey asked marked officers Orick and Nagy to stop the Challenger; when they activated their lights, Craver reversed, striking a vehicle, then accelerated forward and struck a heavy-set man standing at his driver-side window, who rolled onto the hood and then onto the ground.
Craver then struck another parked SUV and fled through a vacant lot; Detective Orndorff later observed Craver speeding and weaving toward his unmarked vehicle but Craver evaded and escaped.
Craver was indicted for failure to comply with the order or signal of a police officer in violation of R.C. 2921.331(B) and (C)(5) (third-degree felony), waived a jury trial, and was tried before the bench.
The trial court credited the State’s witnesses, found Craver guilty, and sentenced him to 24 months' imprisonment with a ten-year driver’s-license suspension.
Craver appealed, arguing (1) the conviction was against the manifest weight and unsupported by sufficient evidence, and (2) trial counsel was ineffective for failing to file a motion to suppress the stop and identification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient / conviction against manifest weight for R.C. 2921.331(B) and (C)(5) (operation caused substantial risk of serious harm)	State: Credible testimony showed Craver willfully fled after signal, struck a person and vehicles, drove recklessly and at high speed, creating a substantial risk of serious physical harm.	Craver: No proof vehicle proximately caused serious physical harm or a substantial risk; conviction against manifest weight.	Court: Affirmed. Evidence legally sufficient; trial court credibility findings reasonable; not against manifest weight.
Whether counsel was ineffective for failing to move to suppress the initial stop and Humphrey’s identification	State: Stop lawful because Humphrey knew Craver lacked a valid license and observed him driving; identification reliable (familiarity, daylight, binoculars).	Craver: Counsel should have filed motions to suppress stop and ID.	Court: Affirmed. Counsel not ineffective—suppression motion would have failed (probable cause/reasonable suspicion and reliable ID).

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for manifest-weight review)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility determinations for factfinder)
State v. Dennis, 79 Ohio St.3d 421 (Ohio 1997) (sufficiency review—Jackson standard)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (reasonable-finder standard for sufficiency of evidence)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong ineffective-assistance test)
Kimmelman v. Morrison, 477 U.S. 365 (U.S. 1986) (meritorious-suppression-basis required for IAC claim based on failure to move to suppress)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (reasonable, articulable suspicion standard for brief stops)
State v. Madrigal, 87 Ohio St.3d 378 (Ohio 2000) (failure to file suppression motion not per se ineffective)
State v. Nields, 93 Ohio St.3d 6 (Ohio 2001) (prejudice inquiry where suppression would have affected outcome)