State v. Williams, 2024 Ohio 311

Alvon L. Williams was stopped by Trooper Lee after his vehicle crossed a marked lane and struck a concrete median at night; the stop was triggered by observed traffic infractions and subsequent suspicion of impairment.
Trooper Lee observed indicia of intoxication (bloodshot eyes, odor of alcohol) and administered field sobriety tests, allegedly conducted according to NHTSA guidelines.
Mr. Williams performed poorly on field sobriety tests, admitted to consuming two Southern Comfort drinks, and later registered a 0.125 BAC (over the legal limit) on a breathalyzer test.
Williams was charged with OVI—both impaired driving and per se violation—and marked lanes violation; convicted by a jury on both OVI counts (impaired driving used for sentencing).
On appeal, Williams argued the breathalyzer results should have been excluded and that the OVI conviction was against the manifest weight of the evidence; he had not objected to the breathalyzer in the trial court nor asserted plain error on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of breathalyzer test results	Williams: Results should be barred	State: No pre-trial/rule-based objection or plain error claimed; admission proper	No plain error or objection; admission affirmed
Conviction against manifest weight of the evidence	Williams: Evidence insufficient	State: Substantial evidence (officer report, tests, admission, BAC) supports conviction	Jury’s verdict supported by credible trial evidence

State ex rel. Quarto Mining Co. v. Foreman, 79 Ohio St.3d 78 (1997) (failure to object at trial waives issues except for plain error)
State v. Rogers, 143 Ohio St.3d 385 (2015) (appellant bears burden to show plain error affecting the outcome)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (standards for manifest weight challenges and appellate review)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility determinations lie primarily with the trier of fact)