Background
Ronald E. Hedges, Jr. was cited under Columbus City Code 2131.08(a)(1) after his vehicle collided with another vehicle on I-270. The ordinance requires a driver to ascertain that a lane movement can be made safely before changing lanes.
At a bench trial, the other driver testified that he moved from the right lane into the center lane to pass a semi-truck, accelerated slightly, and then saw Hedges signal and quickly move from the left lane into the center lane. He or his vehicle’s emergency-braking system braked, but a collision followed. A dashcam video was admitted. Hedges testified that he checked his side mirror, believed the center lane was clear, and saw the other vehicle farther back in the right lane. The municipal court found him guilty and imposed a $75 fine plus costs.
The Court’s Holding
The Tenth District affirmed. It rejected Hedges’s sole argument that his conviction was against the manifest weight of the evidence.
The appellate court deferred to the trial court’s role as factfinder in assessing witness credibility. Even if Hedges checked his mirrors before changing lanes, the evidence supported the finding that the move into the center lane was not safe when he made it. The court concluded that the trial court did not clearly lose its way or create a manifest miscarriage of justice.
Key Takeaways
- An unsafe-lane-change violation turns on whether the driver ascertained that the lane movement could be made safely.
- Checking mirrors does not compel an acquittal when the evidence shows the lane change was unsafe.
- On manifest-weight review, an appellate court gives substantial deference to the trial court’s credibility findings after a bench trial.
Why It Matters
The decision illustrates the limited scope of manifest-weight review in traffic cases tried to the bench. Competing accounts of a collision will not warrant reversal where the factfinder could reasonably credit testimony and video evidence showing that a lane change was unsafe.