State v. Willey, 46 N.E.3d 1121

Memorial Day evening, officers responded to a 911 report of a female assailant "choking out" a man at 501 N. Mill St.; caller lived nearby and reported seeing a woman with a baby.
Officers found appellant Brandi Willey and another woman (Tiffany) on the front porch; children were heard crying inside.
Willey refused to cooperate, repeatedly talked over officers, prevented Tiffany from speaking, and escalated conduct when her boyfriend Jerry Wright emerged and was handcuffed.
Police handcuffed Willey for officer safety; the scene calmed and other occupants confirmed a prior domestic incident and that “Nicky” (a third person) had left.
Willey was indicted for obstructing official business (R.C. 2921.31(A)); she moved to suppress porch entry, was convicted after a jury trial, and appealed arguing insufficiency/weight of the evidence and suppression error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient / conviction against manifest weight for obstructing official business	State: Willey’s active, loud, obstructive conduct and silencing of witnesses impeded officers’ investigation and satisfied the "act" and intent elements.	Willey: Her refusal to cooperate was merely omission or benign speech, insufficient to constitute obstructing official business.	Affirmed — court found affirmative obstructive acts and intent; conviction supported and not against manifest weight.
Whether trial court erred in denying motion to suppress (porch/curtilage and investigatory stop)	State: Officers began with a consensual encounter that became focused on Willey due to her conduct; entry to porch was limited and objectively reasonable given scene escalation and officer safety.	Willey: Officers lacked reasonable suspicion to continue detaining her; police entry onto porch invaded curtilage under Jardines and violated Fourth Amendment.	Affirmed — court found Jardines inapplicable, facts supported consensual encounter → investigation, and no suppression error.

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) (standard for sufficiency of evidence review)
State v. Freeman, 64 Ohio St.2d 291 (Ohio 1980) (Terry-stop/brief investigative detention principles)
Florida v. Jardines, 133 S. Ct. 1409 (U.S. 2013) (use of police to investigate home/curtilage can be a Fourth Amendment search)
Florida v. Rodriguez, 469 U.S. 1 (U.S. 1984) (consensual encounter principles)
Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consensual encounter and freedom to decline police requests)
Adams v. Williams, 407 U.S. 143 (U.S. 1972) (investigative stops without probable cause permissible on reasonable suspicion)
State v. Brooks, 75 Ohio St.3d 148 (Ohio 1996) (suppression-review standards and trial court deference)