State v. Crawford, 2013 Ohio 4398

Crawford was convicted of obstructing official business (R.C. 2921.31(A)), a misdemeanor of the second degree.
The July 18, 2012 incident involved Dayton Police executing a search warrant at 138 South Sperling Ave.
Detective Orick testified Crawford yelled “Police” and slammed the front door as officers approached.
Detectives entered with a battering ram and located seven individuals, including Crawford.
Crawford argued the actions did not impede the officers; trial court found him guilty on Sept. 13, 2012 and sentenced him on Oct. 23, 2012 to 90 days with partial credit and costs.
On appeal, the assignment of error contends the conviction is not supported by the evidence; the appellate court reversed and vacated the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction is supported by the weight of the evidence	Crawford argues actions did not hinder officers	State contends yelling and door closure impeded execution	Sustained; conviction reversed and vacated.

State v. Harrell, 2d Dist. Montgomery No. 21736 (2007-Ohio-4550) (affirmative act needed to hinder police; mere refusal to cooperate insufficient)
State v. Prestel, 2d Dist. Montgomery No. 20822 (2005-Ohio-5236) (requires overt act to impede and actual hindering)
State v. Christman, 2d Dist. Montgomery No. 19039 (2002-Ohio-2915) (must be an affirmative act to hinder duties, not mere noncompliance)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight issues for jury; deference to witness credibility)
State v. McKnight, 107 Ohio St.3d 101 (2005-Ohio-6046) (sufficiency vs weight; different standards; appellate deference)