State v. Hampton, 2018 Ohio 3320

On Oct. 14, 2016 Officer Brent Bethel found a black Cadillac in a private driveway; he recognized it as belonging to Rodney Hampton.
Bethel approached on foot, knocked on the window, and the driver (Hampton) said, “I’m sorry, officer, you scared me.” The car then reversed out of the driveway.
Bethel chased the vehicle on foot, identified himself as a police officer, and ordered the driver to stop; Hampton accelerated forward twice, forcing Bethel to jump out of the way to avoid being struck.
Hampton was indicted on felony counts of Failure to Comply with Order or Signal of a Police Officer (R.C. 2921.331(B), (C)(5)(a)(ii)) and Obstructing Official Business; he pled not guilty.
At trial the State called Officer Bethel (its sole witness in its case-in-chief); the jury convicted Hampton of Failure to Comply (third-degree felony) and acquitted him of Obstructing Official Business.
The trial court sentenced Hampton to 24 months’ imprisonment; Hampton appealed, arguing insufficient evidence and that the verdict was against the manifest weight of the evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hampton)	Held
1. Sufficiency of the evidence to prove willful eluding and substantial risk of serious physical harm	Bethel’s testimony established Hampton was the driver, received a signal to stop, willfully failed to stop, and his driving caused a substantial risk of serious physical harm (Bethel jumped to avoid being struck).	The State failed to prove each element beyond a reasonable doubt.	Affirmed: Evidence, viewed in the light most favorable to the prosecution, was sufficient to support conviction.
2. Whether the conviction is against the manifest weight of the evidence given credibility issues	The jury heard live testimony from both Bethel and Hampton and could credit Bethel’s account; acquittal on the other count shows careful deliberation.	Bethel was the State’s only primary witness and his credibility was questionable, so the verdict was against the manifest weight.	Affirmed: Appellate court concluded the jury did not lose its way; weight and credibility determinations were for the jury.

State v. Jenks, 61 Ohio St.3d 259 (standard for sufficiency of the evidence)
Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency under due process)
State v. Martin, 20 Ohio App.3d 172 (appellate sufficiency review does not permit reweighing evidence)
State v. Thomas, 70 Ohio St.2d 79 (weight and credibility are for the trier of fact)
State v. DeHass, 10 Ohio St.2d 230 (credibility determinations rest with the jury)
State v. Warner, 55 Ohio St.3d 31 (interpretive discussion of statutory terms used by the court)
State v. Eskridge, 38 Ohio St.3d 56 (standard for affirming when substantial evidence supports verdict)
State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight standard and appellate role as thirteenth juror)
State v. Hunter, 131 Ohio St.3d 67 (explaining rarity of reversing on manifest weight grounds)