State v. Crump, 2021 Ohio 2574

On Aug. 6, 2018, Shawn Crump was arrested and charged with obstructing official business, disorderly conduct, and failing to disclose personal information after an interaction with Cincinnati police.
Officers found a teenage girl standing by a street with a four-foot cardboard sign reading “I’m a th[ie]f,” a swollen thumb, and crying; they began investigating her welfare.
Crump identified himself as the girl’s father, repeatedly pulled her behind him, told officers they could not talk to her, and refused to allow medical personnel to examine her.
Officers requested Crump’s name and address; he gave his full name but refused to provide a street address, saying only he lived “down the street.”
The defense played selected portions of officers’ body-worn camera footage at the bench trial; the court admitted and viewed only the segments shown in court. Crump was convicted of obstructing official business and failing to disclose personal information, acquitted of disorderly conduct, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Whether Crump's refusal to allow exam was privileged parental decision that precludes obstructing-official-business conviction	Police: Crump impeded a lawful welfare investigation into a possibly assaulted child	Crump: Parents have a constitutional liberty to refuse nonurgent medical care for a child, so he had privilege to refuse the exam	Court: Privilege did not extend to impeding a welfare/assault investigation; conviction upheld
2. Whether failure to disclose address was criminal conduct	Police: Officers had reasonable suspicion (investigative detention/Terry stop) and R.C. 2921.29(A)(1) requires disclosure when officer reasonably suspects an offense	Crump: Encounter was consensual and failure to give specific address did not obstruct report completion	Court: Encounter was an investigative detention; refusal to disclose during such a detention violated statute; conviction upheld
3. Whether alleged additional bodycam footage (not shown at trial) warrants reversal	State: Record is limited to what trial court admitted and considered	Crump: Unviewed footage on the submitted DVD undermines convictions	Court: Claims based on evidence outside the trial record are rejected; review limited to admitted record

State v. Jenks, 61 Ohio St.3d 259 (1991) (sets legal standard for sufficiency review)
State v. Martin, 20 Ohio App.3d 172 (1983) (explains "manifest weight" review and reversal standard)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and weight-of-evidence standards)
In re Murray, 52 Ohio St.3d 155 (1990) (recognizes parents' fundamental liberty interest in child custody and care)
Santosky v. Kramer, 455 U.S. 745 (1982) (landmark recognition of parental liberty interest regarding children)
State v. Ishmail, 54 Ohio St.2d 402 (1978) (appellate review limited to the record before the trial court)