State v. Fader, 2018 Ohio 4139

Late on Aug. 30–31, 2017, Officer Anderson spotted a blue Chrysler PT Cruiser and ran its plate; it was registered to Rick Fader, who had an active arrest warrant.
The driver initially gave the name Larry Fader Sr., and provided an SSN and birthdate that matched a different Larry Fader Jr.; officers observed the photo did not match the driver.
After questionin g, the driver first denied being Rick, then identified himself as Rick Fader and was arrested on the outstanding warrant.
Fader was charged with one count of obstructing official business (R.C. 2921.31(A)), pled not guilty, represented himself at trial, and was convicted by a jury.
The trial court sentenced Fader to 90 days (87 suspended), one day credit, $100 fine; imposition stayed pending appeal. Fader appealed claiming insufficient evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove obstructing official business under R.C. 2921.31(A)	State: Fader, without privilege, purposefully gave a false identity which hampered the officer’s investigation, meeting the statute’s elements	Fader: The State failed to prove lack of privilege and that his false ID actually hampered or impeded the officer	Affirmed: Sufficient evidence that Fader knowingly gave false information without privilege and that it impeded the officer’s duties

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for sufficiency-of-the-evidence review)
State v. Jenks, 61 Ohio St.3d 259 (1991) ( appellate test for sufficiency review)
State v. Lazzaro, 76 Ohio St.3d 261 (1996) (unsworn false oral statements to public officials can constitute obstructing official business)
State v. Wellman, 173 Ohio App.3d 494 (2007) (proof of intent may be inferred from circumstances; delay need not be substantial in time)
State v. McLaughlin, 48 N.E.3d 987 (2015) (affirming that short delays can still constitute impediment under R.C. 2921.31)