State v. Walters
2017 Ohio 793
| Ohio Ct. App. | 2017Background
- On July 28, 2016, Dustin Mark Walters was charged with reckless operation in violation of R.C. 4511.20 (minor misdemeanor) after a traffic complaint about a speeding motorcycle.
- Trooper Matthew Gardner observed a black motorcycle he estimated at ~80 mph on U.S. 24 and later watched the motorcycle pass between a semi truck and a passenger car, effectively creating a third lane on a two-lane road.
- Walters appeared pro se on August 17, 2016, pled no contest, and the court found him guilty; the court imposed a six-month license suspension, fine, and costs.
- Walters appealed, arguing his conviction was based on insufficient evidence and was against the manifest weight of the evidence, specifically contesting that he acted willfully or wantonly.
- The trial court credited Trooper Gardner’s testimony over Walters’s self-serving statements that he was not speeding and that there was 15–20 feet between the semi and car.
- The appellate court reviewed sufficiency and manifest weight standards and affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to prove Walters acted willfully or wantonly under R.C. 4511.20 | State argued Trooper Gardner’s observations (high speed and passing between semi and car) supported willful or wanton conduct | Walters argued there was insufficient evidence he acted willfully/wantonly; he denied speeding and claimed safe spacing | Affirmed: viewing evidence in prosecution’s favor, a rational trier of fact could find willful/wanton conduct |
| Whether conviction was against the manifest weight of the evidence | State relied on Trooper Gardner’s credible testimony | Walters claimed contrary facts (not speeding; adequate gap; slow pass) and argued trial court erred in crediting the trooper | Affirmed: trial court did not clearly lose its way; credibility determinations supported conviction |
Key Cases Cited
- Thompkins v. State, 78 Ohio St.3d 380 (1997) (distinguishes weight and sufficiency standards)
- Jenks v. Ohio, 61 Ohio St.3d 259 (1988) (standard for sufficiency review)
- DeHass v. State, 10 Ohio St.2d 230 (1967) (deference to trier of fact on credibility)
- Earlenbaugh v. State, 18 Ohio St.3d 19 (1985) (definitions of willful and wanton conduct)
- Martin v. Ohio, 20 Ohio App.3d 172 (1983) (manifest-weight test language quoted)
- State v. Hunter, 131 Ohio St.3d 67 (2011) (rare reversal on manifest-weight grounds)