State v. LaughlinState v. Laughlin
{¶ 1} Appellant, Corey Laughlin, appeals the judgment of the Erie County Municipal Court, follоwing a bench trial, which found him guilty of speeding. For the reasons that follow, the trial court’s judgment is affirmed.
I. Statement of the Case and Facts
{¶ 2} Laughlin was cited for speeding on Route 250 near Scheid Rd. in Erie Township, Erie County, Ohio. More specifically, he was cited for operating his Dodge RAM at a speed of 84 MPH in a 55MPH zone, in violation of
Testimony
Erie County Sheriff Deputy Josh Miller
{¶ 3} The State first called Erie County Deputy Sheriff Josh Miller. Miller was on duty in uniform in a marked patrol car on July 26, 2025, around 6:50 p.m., on U.S. 250 in Huron Township, Erie County. He received radio information from Sgt. Szakats аbout a dark gray pickup traveling northbound at a high rate of speed. Miller did not observe the initial speeding violation himself. He saw a gray or silver pickup with dark tinted windows among a group of vehicles near Kalahari, initiated a stop, and identified the driver as Corey Laughlin. He stated no оther vehicles in the area matched the sergeant’s description at the time of the stop.
{¶ 4} Miller’s body camera was activated after the call; his dash cam activates upon initiating lights. He recalled Laughlin and a passenger disputing that they were speeding. He affirmed the vehiсle had heavily tinted windows and dark grille accents and that no other similar vehicles passed his location between 6:53 and 6:55 or turned on/off Route 250 during his observation. He confirmed this was the first Ram he encountered after being asked to locate the vehicle.
Erie County Deputy Sargeant Brett Szakats
{¶ 5} The next and final witness called by the State was Erie County Deputy Sargeant Brett Szakats. Szakats, an Erie County Sheriff’s sergeant since 2013 with OPOTA certification, was on night shift duty on July 26, 2025. At approximately 6:53 p.m. on U.S. 250 between Huron Avery and Scheid Roads, he observed a pickup
{¶ 6} Bеcause of heavy traffic he could not safely pull out, so he radioed Deputy Miller to locate and stop the vehicle. He described the vehicle by radio as a gray pickup with blacked-out or dark windows and later confirmed the stopped vehicle was the same one he observed. He stated there were no other vehicles in the area matching that description and that Laughlin denied speeding when contacted. On cross, he agreed color description could be subjective between gray and silver and acknowledged he lost sight of the vehicle while merging into traffic. He estimated roughly two miles to the stop location, with Kalahari between, and said two intersections were along that stretch. He affirmed other traffic was present when the truck passed but maintained the speeding vehicle stood out relative to traffic flow and believed it was in the left lane.
{¶ 7} He also recalled Laughlin mentioning his daughter’s Life360 speed data but did not review it. He agreed he said “nearly 90” on radio as an estimate and that his log reflected a radar range of 80–84 mph, which he attributed to acceleration. Dash cam video from his cruiser showed him traveling toward the stop, and he estimated about a minute from callout to Miller’s stop and roughly two minutes for him to arrive. On redirect, he noted cloudy conditions that could diminish visibility but said he could
Appellant-Corey Laughlin
{¶ 8} Corey Laughlin admitted he was the driver and owner of the stopped Dodge Ram. He testified his truck color is silver metallic and offered two photos, one of his silver Ram and one of a dark gray Ram, taken the same day in the courthouse lot. He identified thе other Ram’s color as granite metallic and stated both vehicles appeared the same model aside from color. On cross, he confirmed his front windows had additional non-factory tint and that his vehicle is a Night Edition with black accents. On recross, he stated his back windows are faсtory tinted, while the front door windows and windshield strip are aftermarket and darker than factory.
II. Assignment of Error
{¶ 9} In his sole assignment of error, Lauglin argues that his conviction for speeding was not supported by a sufficiency of the evidence and was against the manifest weight of the evidence.
{¶ 10} As an initial matter, we will note appellee’s observation that Laughlin did not make a Crim.R. 29 motion for acquittal after the State rested its case or after the defense rested its case. However, the Supreme Court of Ohio has held that the failure to object at trial to the insufficiency of the evidenсe does not waive a defendant‘s right to raise the challenge on appeal. State v. Jones, 91 Ohio St.3d 335, 346 (2001); State v. Carter, 64 Ohio St.3d 218, 223 (1992). State v. Messer, 2017-Ohio-1223, ¶ 16 (6th Dist.). In either event, appellant did present an insufficiency of the evidence argument to the trial court in closing argument.
{¶ 12} Appellant also asserts Deputy Miller’s testimony that dash cam could misrepresent dark gray as silver was unreasonable, further undermining reliable identification of the truck. He argues the speed proof was insufficient because the sergeant gave inconsistent speed statements, reporting “nearly 90” and later “80 to 84,” and could not rule out interference from other traffic. Laughlin further maintains the sergeant admitted he could not be sure other traffic did not affect the radar reading, which prevents proof beyond a reasonable doubt.
{¶ 13} Appellant emphasizes the defense offered evidence showing the truck was metallic silver, which contrasted with the sergeant’s “dark gray” identification, creating reasonable doubt on identity. Laughlin argues that without a confirmed speed, driver identification, or plate information, the State presented only a generic description of a common truck and hence, no rational factfinder could find all essential elements proven beyond a reasonable doubt.
Laughlin’s conviction is supported by sufficient evidence.
{¶ 14} This court‘s review of the sufficiency of the evidence presents a legal issue that we review de novo. State v. Dent, 2020-Ohio-6670, ¶ 15. When reviewing whether
{¶ 15} The State charged Laughlin with speeding under
{¶ 16} The evidence adduced at trial established that a highly trained and experienced sergeant with the Erie County Sheriff’s office observed appellant‘s vehicle traveling at a high rate of speed in a 55-mile-per-hour zone.
{¶ 17} The testimony of the officer‘s training and experience and usе of the police radar equipment was admitted without any objection. The officer testified that his radar unit registered a speed of 84 mph and that at the time he observed appellant’s vehicle, there was no other traffic that might have interfered with the radar. The unit emitted a high-pitched tone when appellant’s vehicle passed. Sergeant Szakats visually observed the pick-up truck. He described it as “gray, a gray pickup truck, a gray vehicle, something to that effect.” Laughlin described his vehicle as “silver metallic.”
{¶ 18} Appellant’s primary factual challenge in this appeal is that the officer misidentified the color of the vehicle stopped. Laughlin submitted pictures to the trial
{¶ 19} Nevertheless, Laughlin admitted that he was opеrating his vehicle on State Route 250 when he was pulled over by Officer Miller.
{¶ 20} Appellant’s claim of insufficiency of evidence is a challenging endeavor under the facts of this case. Laughlin must show not merely that the officer described the vehicle‘s color inaccurately, but that this inaccuracy affirmatively demonstrates the wrong vehicle was stopped. And further, that no reasonable factfinder could have credited the officer‘s testimony.
{¶ 21} Sargeant Szakats affirmed other traffic was present when the truck passed but maintained the speeding vehicle stood оut relative to traffic flow and believed it was in the left lane. He described the vehicle by radio as a gray pickup with blacked-out or dark windows and later confirmed the stopped vehicle was the same one he observed. He stated there were no other vehicles in the area matching that description.
{¶ 22} Deputy Miller also testified that he saw a gray or silver pickup with dark tinted windows among a group of vehicles near Kalahari and initiated a stop. He stated no other vehicles in the area matched the sergeant’s description at the time of the stop. Laughlin admitted he was operating his Dodge Ram on Route 250 when he was stopped. The color discrepancy asserted by him in this instance is immaterial. The relevant inquiry is whether, after viewing the evidence in a light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime proven beyond a
{¶ 23} Here, the evidence presented at trial showed that Laughlin was the operator of his Dodge Ram on State Route 250 exceeding the posted 55 mph speed limit which is sufficient to support his for speeding and in violation of
Laughlin’s conviction is not against the manifest weight of the evidence.
{¶ 24} Finally, Laughlin argues that his conviction is against the manifest weight of the evidence becаuse neither Sergeant Szakats nor Deputy Miller were credible concerning the color of the truck. Appellant also argues that Sergeant Szakats was not credible because he “couldn’t state a specific rate of speed nor affirmatively state that the other traffic didn’t interfere with the reading.
{¶ 25} However, contrary to these assertions, Sergeant Szakats testified as follows:
Q What, if any, speed did you observe on the radar unit that indicated to you the Defendant was committing a traffic violation?
A I believe it was 84 in a 55.
{¶ 26} Further, he also testified as follows:
Q All right. What, if any, other traffic might have inferred – interfered with the radar reading of the Defendant’s vehicle?
A There – there was none at that point.
{¶ 27} Laughlin claims that the trial court lost its way in convicting Laughlin.
{¶ 28} A manifest weight of the evidence challenge looks to whether the state met its burden of persuasion. State v. Reillo, 2026-Ohio-2701, ¶ 24. Weight of the evidence concerns:
the inclination of the greater amount of credible evidence, offered in a trial, to support one side of the issue rather than the other. It indicates cleаrly to the jury that the party having the burden of proof will be entitled to their verdict, if, on weighing the evidence in their minds, they shall find the greater amount of credible evidence sustains the issue which is to be established before them. Weight is not a question of mathematics, but depends on its effect in inducing belief.
Id. at ¶ 25, citing State v. Thompkins, 78 Ohio St.3d 380 (1997) (emphasis in original). “Acсordingly, under a manifest-weight review, a court weighs the evidence and all reasonable inferences, considers the credibility of witnesses and determines whether in resolving conflicts in the evidence, the jury clearly lost its way and created such a manifest miscarriage of justice that the conviction must be reversed and a new trial ordered.” Id. at ¶ 26, citing State v. Brown, 2025-Ohio-2804, ¶ 30. “Appellate courts may vacate a jury’s verdict and order a new trial only in the exceptional case in which the evidence weighs heavily against the conviction.” Id. at ¶ 27.
{¶ 30} After carefully reviewing the record, we are not convinced that the evidence contradicts the trial court’s findings or that any witnesses’ testimony was so inconsistent, so impeached, or so fantastical to rеnder it patently unbelievable. As a result, we are bound to give the evidence the interpretation that is most favorable to sustaining the verdict. Id. at ¶ 14. That is, the trial court found that “the testimony was pretty clear that it was the same truck that he was looking for.” We cannot say that the trial court lost its way or created a manifest miscarriage of justice by believing the testimony of the officers. We find, therefore, that Laughlin’s conviction is not against the manifest weight of the evidence. Thus, his sole assignment error is not well-taken.
{¶ 31} For the foregoing reasons, the judgment of the Erie County Municipal Court is аffirmed. Laughlin is ordered to pay the costs of this appeal under App.R. 24.
Judgment affirmed.
A certified copy of this entry shall constitute the mandate pursuant to App.R. 27.
Thomas J. Osowik, P.J.
JUDGE
Gene A. Zmuda, J.
JUDGE
Charles E. Sulek, J.
JUDGE
CONCUR.
This decision is subject to further editing by the Supreme Court of Ohio’s Reporter of Decisions. Parties interested in viewing the final reported version are advised to visit the Ohio Supreme Court’s web site at: http://www.supremecourt.ohio.gov/ROD/docs/.