A man’s overly affectionate social media posts to a former classmate he had never spoken to, coupled with showing up at her apartment and turning the doorknob, provided enough evidence to convict the man of menacing by stalking, the Supreme Court of Ohio ruled today.

In a unanimous opinion, the Supreme Court affirmed a Twelfth District Court of Appeals decision finding Dorrian Crawl stalked a West Carrollton woman by first expressing his love for her online and then appearing at her apartment to find out why she had not responded to his posts. Crawl, and the victim, identified in court records as “A.P.,” went to grade school together more than a decade before the encounter but were never friends.

Crawl argued he could not be convicted of menacing by stalking because the crime requires engaging in a “pattern of conduct” that could lead a person to believe the offender could cause them physical harm or mental distress. He maintained his only harmful behavior was going to A.P.’s apartment, and that non-threatening social media posts were not engaging in a pattern of conduct that could cause mental distress.

Writing for the Court, Justice Megan E. Shanahan stated that a pattern of conduct includes all actions and incidents, “even if some of them, viewed in isolation, do not seem threatening.”

“Even if Crawl did not intend to cause A.P. mental distress, a rational trier of fact could find that he knew that causing A.P. mental distress was the probable cause of his actions,” Justice Shanahan wrote.

Classmate Follows Up on Ignored Social Media Posts
In May 2022, A.P. turned 29 and was celebrating her birthday. She posted a photo on her Instagram account and wrote, “29, be great to me.” Crawl commented on A.P.’s post by first sending a “sad” emoji and then writing, “Happy Birthday, baby girl. I love you. Hope we can see each other sometime soon.” A.P. did not respond to Crawl. Six days later, A.P. posted a video on her Instagram account. Crawl commented by writing, “Where is this, [A.P.]? Is this your house, boo?”

Less than a month later, Crawl appeared at A.P.’s front door. He found her address through an internet search. He knocked on the door, and A.P. looked through the peephole and saw him. She asked who was there, and he said, “It’s Dorian. I’m [A.P.’s] friend. I’m here to see her.” Crawl then turned the doorknob.

A.P. deadbolted the lock and ran to the back of her apartment, where her 9-year-old daughter was located. She put her daughter in the closet and called West Carrollton police.

Crawl was not at A.P.’s when the officer arrived. The officer testified at Crawl’s trial that when he first contacted A.P. she was visibly upset, crying, and nervous. The officer found Crawl, who told him that he went to school with A.P. during their teenage years but that they were not friends and never talked to each other at school.

Crawl told the officer he believed there was a potential relationship with A.P. and  was trying to contact her to “follow up on that.”

The officer noted that Crawl wanted to find out why she had not asked him to prom and why they had not had a relationship. He also told the officer he did not like how A.P. had responded to him. Even after the officer confronted Crawl about appearing at A.P.’s home uninvited, Crawl sent messages to A.P. on social media.

Victim’s Fright Contributed to Conviction
Crawl was charged with menacing by stalking, a violation of R.C. 2903.211(A)(1). At his trial in municipal court, A.P. testified that the incident caused her significant anxiety. It prompted her to install cameras around her apartment and have her boyfriend stay over more often because she was uncomfortable staying alone. She also made sure she was on the phone with someone when she came home late at night, and she started to look for another place to live. While on the witness stand, she said she felt like she was going to throw up and that her heart was pumping out of her chest.

The court found Crawl guilty of the stalking offense. He appealed the decision to the Twelfth District, which upheld the conviction.

Crawl challenged the sufficiency of the evidence against him and argued to the Supreme Court that non-threatening public social media comments, when there is no relationship between the person posting on social media and the commenter, cannot be considered part of the crime of stalking. He maintained that because A.P. did not respond to the posts or let him know she considered them offensive, unwanted, or threatening, he could not have known the posts would cause her emotional distress.

Supreme Court Analyzed Stalking Law
R.C. 2903.211(A)(1) states, “No person by engaging in a pattern of conduct shall knowingly cause another person to believe that the offender will cause physical harm to the other person or a family or household member of the other person or cause mental distress to the other person or a family or household member of the other person.” 

Justice Shanahan explained that “pattern of conduct” means two or more incidents closely related in time. In cases of stalking, explicit threats are not necessary to establish the offense, and nonverbal actions can be part of the pattern if it is reasonable to believe the conduct would cause a person fear of harm or mental distress.

The Court also examined the definition of “mental distress,” which includes any mental illness or condition that would normally require psychiatric or psychological treatment or other mental health services. The opinion noted that mental distress does not need to be incapacitating or debilitating, and a trial court may rely on its own knowledge and experience to determine if a victim suffered mental distress.

The Court found that Crawl’s actions were a pattern of conduct. The opinion noted his “inappropriate social-media messages, including professing his love for A.P.” and asking if her video showed her home, followed closely in time by him showing up to her apartment uninvited and attempting to enter by turning the doorknob. He also continued to message A.P. after being confronted by the police.

The Court found these were two or more actions closely related in time that demonstrated a pattern of conduct that caused A.P. and her daughter mental distress.

“After his discussion with the officer, Crawl was unquestionably on notice that A.P. did not want to be contacted by him,” the opinion stated.

Crawl argued the law required that he acted “knowingly,” and he denied he intended to cause A.P. mental distress. The Court stated a person acts “knowingly, regardless of purpose, when the person is aware that the person’s conduct will probably cause a certain result or will probably be of a certain nature.”

The Court rejected Crawl’s arguments that A.P.’s lack of response to his non-threatening online comments left him unable to know if she was offended. The opinion noted that explicit threats are not required to prove the crime, and A.P. was not required to block Crawl on social media or reject his advances. The Court noted that those types of actions may help a judge or jury determine if an offender acted knowingly, but are not necessary to prove stalking.

While Crawl’s social media comments might have been insufficient to support a finding that he knowingly attempted to cause A.P. mental distress, his actions “went beyond the act of posting inappropriate comments,” the Court stated. His comments, followed by showing up at A.P.’s home uninvited and attempting to gain access, were sufficient to support his conviction, the Court concluded.

2024-0532. State v. Crawl, Slip Opinion No. 2025-Ohio-2799.

View oral argument video of this case.

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