State v. Hefflinger
2017 Ohio 7100
| Ohio Ct. App. | 2017Background
- On Sept. 16, 2016 Suann Hefflinger rear‑ended a stopped school bus; she told officers she fell asleep after taking medication.
- Officer Jared Oliver observed lethargy, disorientation, and knew Hefflinger from prior contacts; he found a prescription bottle with 15 clonazepam pills in her car (90 prescribed 2 weeks earlier).
- At the hospital Hefflinger refused a urinalysis; a recorded conversation captured her admitting she knew she should not drive after taking medication and that she fell asleep.
- Hefflinger pleaded guilty to assured‑clear‑distance, proceeded to a bench trial on remaining counts, and was found guilty of OVI (drug), refusal to submit to chemical test, and failing to stop for a school bus.
- Trial court sentenced her to 120 days jail for OVI, merged/dismissed the chemical‑test count, and imposed fines on the traffic counts.
- Hefflinger appealed, arguing (1) conviction against manifest weight, (2) insufficient evidence, and (3) ineffective assistance of counsel.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Hefflinger) | Held |
|---|---|---|---|
| Sufficiency of evidence that Hefflinger was under the influence of a drug of abuse while operating a vehicle | Officer testimony of impairment + admission she took clonazepam + pills found in car suffice without expert testimony | State needed expert medical testimony or field sobriety tests to link clonazepam ingestion to impairment | Conviction upheld: officer lay testimony plus evidence of clonazepam intake was sufficient (no expert required) |
| Manifest weight of the evidence | Evidence (officer observations, recorded admission, pill bottle, bus driver testimony) supports conviction | Conviction is against the manifest weight because no field tests or expert linking drug to impairment | Not against manifest weight; appellate court defers to trial court credibility findings |
| Ineffective assistance — stipulation of medical records | Stipulation was tactical and records were non‑prejudicial | Counsel erred by stipulating to medical records | Not ineffective; stipulation was reasonable and records contained no damaging information |
| Ineffective assistance — guilty plea to assured clear distance prior to trial | Plea supported by evidence (she admitted falling asleep and bus driver saw no attempt to stop) | Counsel should have preserved civil‑liability defenses via no contest plea; Crim.R.11 warnings were not given | Not ineffective; plea did not prejudice civil claims and Hefflinger did not show the plea was unknowingly entered |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishes sufficiency from manifest weight review)
- State v. Williams, 74 Ohio St.3d 569 (Ohio 1996) (standard for sufficiency review)
- State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (Jenkins/Jenks sufficiency standard)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong test for ineffective assistance of counsel)