State v. Fields, 2020 Ohio 5538

Early morning stop after officer observed a black Honda Civic parked with driver (Fields) head down, then followed the vehicle after it ran a red light and turned into a gas station without signaling.
Officers approached; Fields refused to provide identification, opened the door, smelled of alcohol, had bloodshot/glassy eyes and slurred speech; he refused orders to exit and furtively reached under the seat, requiring officers to forcibly remove and place him in a cruiser.
After arrest, Fields was advised of Miranda rights, transported to jail, and refused to provide a breath sample or sign the BMV-2255 chemical-test form.
Indicted on two OVI counts (R.C. 4511.19(A)(2)(b) — repeat offender). Fields filed then withdrew a motion to suppress before the hearing; jury convicted after trial; counts merged for sentencing.
Sentence: 120 days mandatory plus an additional 30 months under the repeat-offender statute. Fields appealed, raising (1) ineffective assistance for withdrawing the suppression motion, (2) sufficiency/manifest-weight of evidence, and (3) sentence not supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Ineffective assistance — counsel withdrew motion to suppress	State: counsel's withdrawal was a tactical decision and not objectively unreasonable	Fields: withdrawal deprived him of a fair trial because suppression would have succeeded	Court: Overruled — record shows suppression would not have succeeded; tactical withdrawal not ineffective assistance
2. Sufficiency / manifest weight of evidence for OVI conviction	State: officer observations (odor, slurred speech, bloodshot eyes, unsteady gait), refusal to test and prior convictions support conviction	Fields: no field-sobriety or breath test, cruiser video lacked audio, officer testimony unreliable	Court: Overruled — rational juror could find OVI beyond a reasonable doubt; verdict not against manifest weight
3. Sentence not supported by record	State: sentence within statutory range and based on PSI and statutory factors	Fields: trial court failed to clearly and convincingly support the imposed sentence	Court: Overruled — sentence lawful, trial court considered R.C. 2929.11/2929.12 (reflected in journal entry), record supports sentence

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance standard)
State v. Bradley, 42 Ohio St.3d 136 (1989) (Ohio adoption of Strickland standard)
Kimmelman v. Morrison, 477 U.S. 365 (1986) (failure to file suppression motion not per se ineffective assistance)
State v. Madrigal, 87 Ohio St.3d 378 (1999) (withdrawing a suppression motion can be tactical)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence)
Brinegar v. United States, 338 U.S. 160 (1949) (probable cause definition)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest-weight review)
State v. Marcum, 146 Ohio St.3d 516 (2016) (appellate standard for felony-sentence review under R.C. 2953.08(G)(2))
State v. Kalish, 120 Ohio St.3d 23 (2008) (presumption that trial court considered statutory sentencing factors)
State v. Arnett, 88 Ohio St.3d 208 (2000) (sentencing discretion and consideration of personal experience)
State v. Cook, 65 Ohio St.3d 516 (1992) (deference to trial-court sentencing judgments)