State v. Campbell, 2014 Ohio 4305

On April 5, 2012, deputies stopped a black Ford Explorer after a report that Benjamin Beckwith (wanted and associated with meth production) had been seen nearby; officers smelled chemicals and observed an object thrown from the vehicle.
Three occupants were detained: appellant Mitchell Campbell (driver), Ashley Beckwith (front passenger), and Benjamin Beckwith (rear passenger).
A duffle/camouflage bag on the back seat emitted a chemical odor and contained items consistent with a methamphetamine one‑pot lab and related supplies; Campbell’s insurance card was found in the bag.
Campbell was indicted on counts of illegal manufacture of methamphetamine (felony II), illegal assembly/possession of chemicals to manufacture drugs (felony III), and aggravated possession (felony V); the aggravated possession count was dismissed at close of the state’s case.
A jury acquitted Campbell of manufacture but convicted him of illegal assembly/possession of chemicals; the trial court sentenced him to 30 months’ imprisonment. Campbell appealed on manifest‑weight and jury‑instruction (complicity) grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conviction for illegal assembly/possession of chemicals is against the manifest weight of the evidence	State: Items suitable for meth lab were in the vehicle in close proximity to Campbell and his insurance card was in the bag, supporting constructive possession	Campbell: True criminal was Benjamin Beckwith in rear seat; he lacked possession/intent	Court: Affirmed — weight of evidence supports constructive possession; jury did not lose its way
Whether giving a complicity instruction was error when Campbell was not charged as an accomplice	State: R.C. 2923.03(F) permits complicity instruction and evidence supported it; defendant had notice	Campbell: Court erred by instructing on complicity absent a complicity charge	Court: No reversible error — instruction permissible under R.C. 2923.03(F); no prejudice and no plain error

State v. Thompkins, 78 Ohio St.3d 380 (weight of the evidence standard for manifest‑weight review)
State v. DeHass, 10 Ohio St.2d 230 (trial court/jury best assesses witness credibility)
State v. Wolery, 46 Ohio St.2d 316 (constructive possession defined as dominion and control)
State v. Jenks, 61 Ohio St.3d 259 (circumstantial evidence may support possession elements)
State v. Pruitt, 18 Ohio App.3d 50 (contraband in close proximity can establish constructive possession)
State v. Yarbrough, 95 Ohio St.3d 227 (plain‑error standard for unobjected‑to jury instructions)