State v. Williams, 2021 Ohio 1359

Early morning single-vehicle crash: Williams' car left Route 68 and rolled; a citizen observed him crawling from the vehicle and called 9-1-1.
Deputy Colton Piatt arrived around 5:00 a.m.; observed Williams walking upset, with a moderate alcohol odor, glassy/bloodshot eyes, unsteadiness, and apparent difficulty following commands.
Piatt asked Williams to perform standardized field sobriety tests; Williams declined. Williams also refused a breath test at the jail, citing COVID concerns and saying he would take a blood test (which he later did not obtain).
Williams testified he had not been drinking, claimed he fell asleep while driving, and disputed some of Piatt’s procedural assertions.
Bellefontaine Municipal Court convicted Williams of OVI (R.C. 4511.19(A)(1)(a)) and several related offenses; Williams appealed raising sufficiency and manifest-weight challenges.
The Third District Court of Appeals affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict for OVI	State: accident, officer observations (odor, glassy eyes, unsteady), refusals to FST and breath test suffice when viewed in the light most favorable to the prosecution	Williams: no direct proof he drank; he fell asleep; refused breath test for COVID; denied being asked to do FSTs	Affirmed: evidence sufficient for a rational trier of fact to find guilt beyond a reasonable doubt
Manifest weight of the evidence	State: credibility of officer and circumstantial evidence support conviction	Williams: testimony and lack of direct proof create reasonable doubt; denial of drinking and alternative explanations (hand sanitizer, fatigue)	Affirmed: appellate court declined to find a manifest miscarriage of justice; trial court’s credibility determinations upheld

State v. Thompkins, 78 Ohio St.3d 380 (1997) (defines manifest-weight standard)
Tibbs v. Florida, 457 U.S. 31 (1982) (appellate court may act as a thirteenth juror in weight review)
Maumee v. Anistik, 69 Ohio St.3d 339 (1994) (refusal to submit to a breath test is admissible evidence)
State v. Hunter, 131 Ohio St.3d 67 (2011) (sufficiency standard: any rational trier of fact could find essential elements proven)
State v. Holnapy, 194 Ohio App.3d 444 (2011) (refusal to perform field sobriety tests admissible as evidence of guilt)
State v. Martin, 20 Ohio App.3d 172 (1983) (manifest-miscarriage-of-justice language controlling weight review)
State v. Thompson, 127 Ohio App.3d 511 (1998) (deference to factfinder on credibility determinations)