[ ] resisting] or interfering] with a lawful arrest of the person or another.” Ohio Rev.Code § 2921.33. As we have already held that the officers lawfully arrested Harris, the sole question is whether the officers had probable cause to believe that he recklessly resisted or interfered with that arrest. A reasonable factfinder could conclude that Harris’s actions — his uncooperative attitude, attempts to “resist[] and try[] to get loose,” unwillingness to accompany the officers to the DEA office and confrontational and threatening statements and gestures — satisfy this requirement, despite the lack of an “actual struggle.” JA 131; see Hansen v. Westerville City Sch. Dist., Bd. of Educ., Nos. 93-3231/93-3303, 1994 WL 622153 at*6, 1994 U.S.App. LEXIS 31576, at *15 (6th Cir. Nov. 7, 1994) (<HOLDING>); see also Palshook, 120 F.Supp.2d at 651.
holding that there is no  1983 cause of action for false arrest unless the arresting officer lacked probable cause holding avoiding arrest is not the same as resisting arrest holding that plaintiff had failed to show officers lacked probable cause to arrest and prosecute him for resisting arrest under ohio law when he pulled his arm away from the officer told him to get your paws off me and struggled with the arresting officers holding that officer had probable cause to arrest for violation of ordinance and that officers failure to cite ordinance either orally or in his arrest report was irrelevant holding that the defendant was placed in official detention when two police officers approached him and told him that he was under arrest as the defendant could not reasonably have believed that he was free to leave