State v. Monnin, 2017 Ohio 1095

Kyle Monnin was indicted for felony failure to comply with a police officer in violation of R.C. 2921.331(B)/(C)(5)(a)(ii) after allegedly fleeing an Ohio State Highway Patrol trooper while riding a lime‑green motorcycle at 111 m.p.h. on I‑75.
Trooper Kunka observed Monnin weaving through heavy traffic, passing cars, driving on the berm, and accelerating after Kunka entered traffic; Kunka then activated lights and siren and pursued.
Due to traffic safety concerns Kunka terminated the high‑speed pursuit; dispatch soon reported a green motorcycle crash on an exit ramp.
Kunka found Monnin in a CVS parking lot injured and sitting on his damaged motorcycle; Monnin waived Miranda rights, admitted he saw the trooper, said he was scared and tried to take the next exit, and gave a written statement corroborating those admissions.
The jury convicted Monnin of willfully eluding a police officer and specifically found his conduct caused a substantial risk of serious physical harm; the trial court sentenced him to 36 months in prison and a five‑year license suspension.
Monnin appealed, arguing (1) Crim.R. 29 acquittal should have been granted, (2) insufficiency of the evidence, and (3) conviction against the manifest weight of the evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Monnin)	Held
Whether evidence was sufficient to deny Crim.R. 29 motion	Testimony, dashcam, written admission, and conduct support each element; a rational juror could convict	State failed to prove Monnin actually received a visible or audible stop signal	Denied; evidence sufficient to submit to jury and support conviction
Whether Monnin received/observed police signal to stop	Dashcam and trooper testimony show lights/siren were activated; Monnin later admitted he saw the trooper	Monnin contends he never saw lights or heard siren and was not within hearing/visual range	Held Monnin’s conduct and admissions supported finding he received the signal
Whether flight was willful (element of elude/flee)	Acceleration, maneuvering through traffic, and attempts to exit the highway after observing the trooper show willfulness	Monnin’s fear and attempt to exit do not negate willfulness	Held evidence supported a finding of willful eluding
Whether conduct created substantial risk of serious physical harm	High speed (111 m.p.h.) in heavy traffic, weaving, driving on berm, and resulting crash/damage posed substantial risk to persons and property	Monnin did not dispute speed/damage but argued insufficiency to prove receipt of signal	Held the evidence showed a substantial risk of serious physical harm

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishes sufficiency and manifest‑weight standards)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (articulates the standard for legal sufficiency review)
State v. Blankenburg, 197 Ohio App.3d 201 (12th Dist. 2012) (deference to jury’s credibility determinations on appeal)