OH7: Obstructing officers from going behind house in alleged violation of curtilage affirmed

Defendant was convicted for obstruction by seeking to prevent officers from going behind his house in alleged violation of his curtilage. The officers, however, could articulate valid reasons for going there because of flight of somebody else behind the house, and the obstruction conviction is affirmed. State v. Albright, 2016-Ohio-7037, 2016 Ohio App. LEXIS 3897 (7th Dist. Sept. 27, 2016):

[*P48] Viewing the evidence in the light most favorable to the state, a rational person could conclude Appellant’s acts in the driveway were without privilege and the officer’s use of the driveway was lawful. At that point, Appellant’s behavior further strengthened the officer’s belief the two males had been drinking while underage. During the suspects’ continued flight to or through the back yard, the officers heard commotion behind the house. That is, after the flight of the suspects to the back yard and before any entry by the officers onto the back porch, the sound of bottles breaking or banging could be heard. As one officer explained, the noise indicated to him that people were trying to hurry and hide the beer.