The Ohio Court of Appeals has upheld the conviction of Jacob Khazrai for violating traffic control laws. The court ruled that the evidence presented was sufficient to support the conviction, which arose from a traffic incident in Perrysburg, Ohio. Khazrai, who represented himself, argued that the trial court made errors regarding evidence and due process. This ruling is significant as it clarifies the responsibilities of defendants in traffic violation cases.
The case, State v. Khazrai, was filed under docket number WD-25-081 and was decided on October 23, 2026. The court's decision affirmed the judgment of the Perrysburg Municipal Court, which had previously found Khazrai guilty of disobeying traffic control devices under Ohio Revised Code 4511.12. Khazrai was fined $50 and ordered to pay court costs.
Jacob Khazrai was pulled over by Trooper Basilius after being observed driving his truck in the left lane of a construction zone where signs indicated that all trucks should use the right lane. Khazrai contested the charge, claiming that there was insufficient evidence to prove that a legally operative traffic control device applied to him at the time of the incident. He argued that the state failed to show that the signage was properly placed and visible.
The court noted that once the prosecution established the existence of a traffic control device, it was presumed to be official and correctly placed. This burden shifted to Khazrai to provide evidence to the contrary. However, the court found that he did not present any substantial rebuttal evidence. Trooper Basilius testified that he confirmed the location of the sign after issuing the citation, and the court found his testimony credible.
In addressing Khazrai's first assignment of error, the court stated, "Given the inference that the sign has been placed properly, the burden switches to the defendant to rebut the inference that the sign was placed in compliance with the OMUTCD." The court also highlighted that Khazrai's own testimony did not sufficiently challenge the officer's account.
Khazrai's second argument claimed that the state's theory of liability was unclear and deprived him of due process. He argued that the prosecution relied on multiple driving theories without establishing a clear statutory violation. The court clarified that Khazrai was charged with a single violation of R.C. 4511.12, and the evidence presented at trial supported this charge.
The court responded to Khazrai's concerns about the clarity of the conviction, stating, "The record of this case demonstrates that appellant’s second assignment of error is without merit, and we find it not well taken and denied." The court emphasized that the trooper's testimony about the construction zone and signage did not create conflicting theories of liability.
In his third assignment of error, Khazrai contended that the trial court violated his due process rights by not specifying the statutory offense or elements supporting the conviction. The court ruled that a general finding of guilt is sufficient after a bench trial, and it is not required to recite specific statutory elements on the record. The court cited previous rulings that supported this position.
Ultimately, the court affirmed the judgment of the Perrysburg Municipal Court, concluding that Khazrai's arguments lacked merit. The court ordered him to pay the costs of the appeal.
This ruling has implications for future traffic violation cases in Ohio. It reinforces the idea that defendants must provide substantial evidence to challenge the presumption of proper signage and compliance with traffic laws. The decision also clarifies the standards for due process in traffic violation cases, emphasizing the sufficiency of general findings of guilt in bench trials.
Looking ahead, it is unclear whether Khazrai plans to appeal the ruling further. The court did not mention any related cases pending in its opinion. However, this decision serves as a reference for similar cases involving traffic violations and the responsibilities of defendants in presenting evidence.