City of Warren v. Patrone

In City of Warren v. Patrone (1991), 75 Ohio App.3d 595, 600 N.E.2d 344, the defendant approached an officer and said that he had something to show her. The officer asked the defendant to leave her alone. Two hours later, the defendant again approached the officer with the parking ticket of a third person. The defendant crumpled the ticket, threw it at the officer, and said, "Here's what people think of your asshole tickets, asshole." 75 Ohio App.3d at 598. The court of appeals found that a reasonable officer would not have been provoked to an immediate breach, and that the trial court erred in finding that the defendant's conduct violated the statute prohibiting disorderly conduct. Id.