State v. Williams, 2021 Ohio 4200

On Dec. 3, 2020 Williams was charged with two second-degree misdemeanors: obstructing official business (R.C. 2921.31) and resisting arrest (R.C. 2921.33).
Officers responded to a report that Williams had entered Cheryl Snoke’s residence through a broken window and would not leave; two female occupants told officers Williams was inside and was "scaring" them.
Officers announced their presence and ordered Williams to exit the home four times; he repeatedly refused, saying he lived there and would not leave, and became belligerent.
Officers entered, attempted to detain him, a physical struggle ensued, one officer deployed a taser, and Williams was handcuffed; body‑cam video and officer testimony were admitted at trial.
Williams waived a jury, was tried in a bench trial, found guilty of both counts, and sentenced to two consecutive 90‑day jail terms (with substantial portions suspended). He appealed, challenging denial of Crim. R. 29 motions and the manifest weight/sufficiency of the evidence for both convictions.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
1. Sufficiency/manifest weight for obstructing official business (R.C. 2921.31)	Williams’ repeated refusal to follow lawful orders and his belligerent conduct were affirmative acts that impeded officers’ duties.	He did not impede officers: he lived at the residence, refused only to leave his home, and answered questions; mere refusal to step outside is not an overt act.	Court affirmed: repeated, noncompliant and physically resistant conduct sufficiently impeded officers; conviction upheld.
2. Sufficiency/manifest weight for resisting arrest (R.C. 2921.33)	Officers had probable cause to detain/arrest once Williams refused orders and physically resisted; his force/reckless interference supports conviction.	There was no lawful arrest or probable cause when officers entered; officers lacked intent to arrest and therefore resisting arrest elements not met.	Court affirmed: probable cause existed when officers detained him after refusal and struggle; resisting‑arrest conviction upheld.

State v. Williams, 74 Ohio St.3d 569 (1996) (Crim. R. 29 / sufficiency framework)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency from manifest‑weight review)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight of evidence assigned to factfinder)
State v. Dennis, 79 Ohio St.3d 421 (1997) (Crim. R. 29 guidance)
State v. Martin, 20 Ohio App.3d 172 (1983) (manifest‑weight test language)
State v. Thompson, 116 Ohio App.3d 740 (1996) (probable‑cause / reasonable basis for arrest)
State v. Wellman, 173 Ohio App.3d 494 (2007) (focus on defendant’s conduct and its effect on officers’ ability to perform duties)