State v. Fork
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In this case, the Supreme Court of Ohio was called upon to interpret the definition of "motor vehicle" as it applied to the crime of aggravated vehicular assault. The defendant, Joshua Fork, was charged with multiple counts, including aggravated vehicular assault, after driving a Polaris under the influence of alcohol and injuring his passengers. At issue was whether the Polaris should be classified as a "motor vehicle" or a "utility vehicle."
The Court ruled that the definition of "motor vehicle" in R.C. 4501.01(B), which applies to penal laws, should be used in the context of aggravated vehicular assault. It also held that the Polaris should be classified as a "utility vehicle," as defined by R.C. 4501.01(VV), based on its principal purpose, not its use at the time of the incident.
The Court reasoned that the principal purpose of the Polaris, as shown by evidence and testimony, was for farm-related activities, such as hauling rocks and bags of seed, removing limbs, pulling a sprayer, and trimming trees. The Polaris's ancillary use for recreation did not affect its principal purpose.
The Court concluded that, since the Polaris fit the definition of a "utility vehicle" under R.C. 4501.01(VV), the evidence admitted at trial was legally insufficient to support Fork’s convictions for aggravated vehicular assault. Consequently, the Court affirmed the judgment of the Sixth District Court of Appeals, which had reversed the trial court's judgment and vacated Fork’s convictions for aggravated vehicular assault.
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