State v. Shannon, 2015 Ohio 438

Police investigated an armed robbery and traced leads to a residence at 812 Allen Street; Christopher Shannon answered the door and appeared nervous and similar in appearance to the robber on surveillance.
Officers entered at the homeowner's invitation; Detective Groomes questioned Shannon in the entryway and asked if he had a gun; Shannon denied it and asked repeatedly what he had done and whether he would go to jail.
Shannon requested to go upstairs/use the bathroom; Groomes asked for a pat-down for safety and began frisking Shannon. While patting Shannon’s left ankle, Groomes felt a pistol grip.
After the grip was felt, Shannon pulled away and attempted to walk up the stairs; Groomes lunged and tackled him, the firearm fell onto the landing, and officers secured and found it loaded.
A grand jury indicted Shannon on multiple weapons counts and obstructing official business with a firearm specification; Shannon pleaded no contest to other counts but proceeded to a bench trial on obstruction and the specification.
The trial court found Shannon guilty of obstructing official business and the firearm specification; he was sentenced to 1 year and 9 months. Shannon appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Shannon)	Held
Sufficiency: whether evidence proves obstruction under R.C. 2921.31(A)	State: Shannon lied about having a gun, pulled away when gun was discovered, and thereby hampered officers’ duties	Shannon: He revoked consent to the pat-down and attempted to terminate the encounter—privileged conduct; brief movement didn’t impede police	Court: Evidence sufficient—Shannon’s lie and pulling away after the gun was felt impeded officers and justified seizure and arrest
Manifest weight: whether conviction is against manifest weight of evidence	State: testimony and events support conviction; credibility and inferences favor prosecution	Shannon: his brief attempt to walk up stairs was insufficient to impede officers (no developed weight argument)	Court: Declined manifest weight analysis because Shannon failed to develop argument; conviction stands

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for reviewing sufficiency of the evidence)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (appellate sufficiency review—view evidence in light most favorable to prosecution)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (officer may conduct limited search for weapons when safety reasonably in question)
State v. Otten, 33 Ohio App.3d 339 (Ohio Ct. App. 1986) (standard for manifest weight review)
State v. McCrone, 63 Ohio App.3d 831 (Ohio Ct. App. 1989) (distinguishing mere refusal from active conduct that impedes officers)