State v. Dale, 2024 Ohio 2001

Bobby Dale, Jr. was stopped by Cincinnati police after exiting his vehicle, entering a closed park, and urinating by a tree late at night.
Officer Lee observed signs of impairment: slurred speech, stumbling, difficulty standing, confusion, and an odor of alcohol; Dale admitted to drinking.
Standardized field sobriety tests (SFSTs) were administered: Dale performed poorly on the walk-and-turn but showed no clues on the one-leg stand; nystagmus was detected during the HGN test.
Dale was arrested for OVI, refused a breath test at the station, and was combative and confused during processing.
Dale moved to suppress evidence from the stop and testing, but motions were denied and a jury convicted him of OVI under R.C. 4511.19(A)(1)(a).
On appeal, Dale argued the conviction was not supported by sufficient evidence and was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for OVI conviction	Officer's testimony and observations established impairment	Lack of traffic infraction, insufficient proof	Sufficient evidence for OVI supported
Manifest weight of the evidence	Jury properly weighed evidence, credibility to Lee	Jury should not have credited SFST results	Conviction not against manifest weight
Admissibility/compliance of SFST administration	Officer substantially complied with NHTSA standards	Officer did not properly conduct SFSTs	SFSTs substantially compliant, admissible
Credibility of HGN results with trainee involved	Lee observed and confirmed HGN clues personally	Lee not properly positioned to observe	Jury credited Lee; no reversible error

State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (reviewing sufficiency of evidence standard for criminal convictions)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (reviewing weight of the evidence standard and appellate review principles)
State v. Martin, 20 Ohio App.3d 172 (Ohio Ct. App. 1983) (defining manifest weight standard for criminal convictions)