State v. Palma, 2025 Ohio 1318

Juan Palma II was convicted by a jury in Butler County, Ohio of three offenses: failure to comply with an order or signal of a police officer (third-degree felony), obstructing official business (fifth-degree felony), and resisting arrest (second-degree misdemeanor).
His convictions arose from a high-speed chase through a residential area, which involved dangerous driving and near-misses with other motorists, and his eventual arrest after hiding from police inside his residence.
Palma was sentenced to 18 months in prison, less credit for time served.
Palma appealed challenging the sufficiency and manifest weight of the evidence for his two felony convictions and the adequacy of the verdict form used for the third-degree felony conviction.
The appellate court reviewed the matters, focusing on the legal definitions and facts supporting the elements required for the felony charges.

Issue	Palma's Argument	State's Argument	Held
Sufficiency/Manifest weight of evidence on felony charges	Evidence did not prove substantial risk of serious physical harm for the third-degree failure to comply, nor risk of physical harm for felony obstruction	State presented sufficient evidence of dangerous high-speed chase and Palma's refusal to surrender increased risks to himself and officers	Convictions supported by sufficient evidence and not against manifest weight
Deficient verdict form for felony failure to comply	Verdict form failed to state degree, statute, or enhancement elements; should not sustain felony conviction	Special verdict form showed the jury found all essential elements elevating charge to a felony	No plain error; form sufficient due to special verdict; conviction affirmed

State v. Jenks, 61 Ohio St.3d 259 (standard for sufficiency of the evidence review)
State v. DeHass, 10 Ohio St.2d 230 (witness credibility is primarily for the trier of fact)
State v. Long, 53 Ohio St.2d 91 (plain error review reserved for exceptional circumstances)