State v. Brown, 2015 Ohio 3407

Defendant Keiwaun M. Brown was indicted on counts of possession of cocaine, possession of heroin (R.C. 2925.11), and obstructing official business after an incident on July 30, 2014.
Officer Casey Johnson saw Brown walking, called his name, and when Brown moved away and crouched near a parked vehicle, Johnson drew his Taser. Brown then bent at the front of the vehicle and appeared to place something under the engine.
Brown fled ~20 yards, lay down in a nearby field, and was arrested. Officers searched and found a cigar pack in front of the vehicle at the spot where Brown bent down; inside were baggies of heroin and cocaine (~$1,400). A slushie and cigar were also found nearby.
At trial Brown argued he did not possess the drugs; his furtive movements and flight were explained by fear of being tased. The prosecution relied on the officers’ observations and the proximity/timing of the discarded cigar pack to prove constructive possession.
A jury convicted Brown on all counts. He was sentenced to concurrent terms yielding an 18‑month aggregate prison term. Brown appealed, challenging sufficiency and manifest weight for the drug convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove possession of cocaine and heroin	State argued officers saw Brown place an item under the vehicle and the cigar pack containing drugs was found at that exact spot, supporting constructive possession	Brown argued the state failed to prove he possessed the drugs; his movements and flight were due to fear of being tased, not to discarding contraband	Convictions upheld — evidence sufficient for constructive possession; jury could credit officers’ testimony
Whether convictions were against the manifest weight of the evidence	State relied on circumstantial proof and credibility of officer testimony	Brown argued the weight of evidence favored acquittal given alternative explanations and context (crowded street, occupants in the car)	Not against manifest weight — jury did not lose its way; circumstantial evidence supported dominion and control

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishes sufficiency from manifest weight review)
State v. Shannon, 191 Ohio App.3d 8 (Ohio App. 2010) (circumstantial evidence can alone support a conviction)
State v. Ballew, 76 Ohio St.3d 244 (Ohio 1996) (circumstantial evidence may be more persuasive than direct evidence)