Lyons v. City of Xenia, 417 F.3d 565, 575 (6th Cir.2005) (recognizing that, “[i]n ascertaining whether a constitutional violation occurred, the only question is whether [the officer] had probable cause — not whether the evidence would be sufficient to support a conviction”). The officers, in short, had probable cause to arrest Harris and to charge him with criminal assault. Second, the officers had probable cause to charge Harris with resisting arrest under § 2921.33 of the Ohio Revised Code, which proscribes “recklessly or by forc Harris’s contrary position more tenuous, Ohio appellate courts have upheld jury verdicts convicting criminal defendants of resisting arrest in circumstances not far different from these. See State v. Keegan, 67 Ohio App.3d 824, 588 N.E.2d 928, 930 (1990) (<HOLDING>); State v. Thomas, No. 2910, 1995 WL 39402,
holding that physical activity which prevents or delays an arrest including going limp is enough to sustain a conviction for resisting arrest under ohio law holding avoiding arrest is not the same as resisting arrest holding that resisting arrest is lesser offense of assault on an officer holding that force exerted against an officer after an arrest is complete cannot be used as the basis for prosecuting one for resisting arrest holding that it is equally wellestablished that a suspects mere flight to escape arrest does not violate the resisting arrest statute