2019 Ohio 1506
Ohio Ct. App.2019Background
- Defendant Laurie Howell, an Aramark employee at Mansfield Correctional Institution, was charged with obstructing official business for allegedly interfering while a corrections officer tried to subdue an inmate who had a contraband cell phone.
- Incident occurred October 2, 2016; bench trial held May 16, 2018 after plea of not guilty.
- Officer Aaron Britt testified the inmate ran into the food-prep area, dropped a phone, and Howell picked it up and approached while he was wrestling the inmate despite his orders to move away. Officer said her conduct hampered his ability to subdue the inmate.
- Howell testified she was attempting to hand the phone to Officer Britt (per her employee duty to surrender contraband), denied prior contact with the inmate, and said the inmate seized and destroyed the phone.
- Trial court found Howell guilty of R.C. 2921.31 (obstructing official business); sentenced to 90 days jail and $200 fine. Appeal challenges sufficiency of evidence as to purposeful intent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to prove Howell acted "purposely" to obstruct a public official in violation of R.C. 2921.31 | State: Howell's affirmative act (picking up/approaching with the phone) despite repeated orders to move away shows purpose and actually hampered the officer | Howell: She intended to hand contraband to the officer per employer duty and did not knowingly impede or communicate with the inmate | Court: Evidence sufficient — intent can be inferred from conduct and circumstances; Howell's actions impeded officer's performance |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for reviewing sufficiency of the evidence)
- State v. Wellman, 173 Ohio App.3d 494 (2007) (intent may be inferred from manner of act and surrounding circumstances)
- State v. Kates, 169 Ohio App.3d 766 (2006) (lists elements of R.C. 2921.31)
- State v. Huffman, 131 Ohio St. 27 (1936) (defendant's intent must be determined from manner, means, and surrounding facts)
- North Ridgeville v. Reichbaum, 112 Ohio App.3d 79 (1996) (purpose may be established by circumstantial evidence)