State v. Shoe, 2018 Ohio 3006

Officer Kevin Calvert responded to a July 17, 2017 complaint about an injured dog in Robert Shoe’s backyard.
Calvert encountered Shoe, asked questions, and requested identification to issue a possible animal-cruelty citation.
Shoe became belligerent, used profane language, repeatedly told the officer to leave, and went into his house multiple times before finally providing ID.
The interaction lasted roughly 30–40 minutes; Calvert estimated about a ten‑minute delay from the ID request to receipt of identification.
Shoe was charged with obstructing official business (R.C. 2921.31(A)) and disorderly conduct; a bench trial found him guilty only of obstructing official business.
Shoe appealed, arguing the State failed to present sufficient evidence that he acted with purpose to obstruct or that the officer was hampered; the Third District affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sufficient evidence supported a conviction for obstructing official business under R.C. 2921.31(A)	Testimony established Shoe acted belligerently, refused/procrastinated on producing ID, retreated into his house, and thereby delayed and impeded Officer Calvert’s investigation	No proof Shoe acted with the specific purpose to prevent/obstruct/delay nor that the officer was actually hampered — mere refusal to identify is insufficient	Affirmed: viewing evidence in the light most favorable to the State, a rational trier of fact could find Shoe committed an affirmative act with purpose to obstruct and that the officer was hampered

State v. Jenks, 61 Ohio St.3d 259 (establishes standard for sufficiency review)
State v. Smith, 80 Ohio St.3d 89 (discussed in relation to Jenks and evidentiary standards)
State v. Puterbaugh, 142 Ohio App.3d 185 (purpose inferred from manner of conduct and circumstances)
State v. Wellman, 173 Ohio App.3d 494 (focus on defendant’s conduct and its effect on officer’s ability to perform duties)