State v. Bell, 2013 Ohio 1299

Bell was indicted on four counts: two counts of trafficking in cocaine with school specifications, one count of possession of cocaine, and one count of possessing criminal tools.
Counts I and II related to December 23, 2010 and January 17, 2011 controlled buys allegedly involving crack cocaine and a confidential informant.
Counts III and IV arose from Bell’s February 3, 2011 arrest, where cocaine residue and a digital scale were found in his possession.
Bell moved for separate trials four days before trial; the court denied the motion.
Jury found Bell guilty on all four counts; he was sentenced to 43 months in prison.
Bell timely appealed raising four assignments of error challenging sufficiency, severance, ineffective assistance, and evidentiary chain-of-custody issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Insufficiency of evidence for trafficking counts	Bell argues evidence fails to prove elements	Bell contends no proof of trafficking near school	Sufficiency satisfied; convictions upheld
Denial of motions to sever trial counts	Bell asserts improper joinder denial	Bell claims severance warranted	No abuse of discretion; denial affirmed
Effective assistance of counsel	Bell claims counsel failed to object to hearsay and authentication	Bell asserts prejudice from objections not raised	No reversible error; claims fail under totality of circumstances
Chain of custody admissibility of exhibit	State failed to establish complete chain of custody	Chain breaks affect admissibility	Chain established; admissible; weight affects only weight of evidence

State v. Monroe, 105 Ohio St.3d 384 (2005) (sufficiency review standard)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (sufficiency and evidentiary considerations)
State v. Robinson, 162 Ohio St. 486 (1955) (sufficiency standard (historical))
State v. Waddy, 63 Ohio St.3d 424 (1992) (joinder and severance considerations)