State v. Carroll, 2017 Ohio 7141

Appellant Jeremiah T. Carroll was indicted and tried for two counts of having weapons under disability (R.C. 2923.13(A)(2)) after a September 27, 2015 incident at a Motel 6 involving assaults and stolen property.
Police, with consent from Appellant’s father, searched the motel room and safe and found 57 grams of marijuana, pills (diazepam and alprazolam), a Smith & Wesson .357 revolver, a Raven .25 handgun, cash, stolen items, and a cell phone.
DNA testing showed about 90% of the DNA on the .357 revolver matched Appellant; no other known participant’s DNA matched.
Forensic analysis of the recovered cell phone linked an email/Facebook account to Appellant and showed internet searches on the morning of the incident for the motel safe brand and pill identification.
Appellant testified he did not possess the guns, claimed the phone belonged to his father (though evidence tied it to him), and denied conducting the searches; the jury convicted him on both counts.
The trial court sentenced Appellant to three years’ incarceration on Count 1 (with post-release control) and three years community control on Count 2; Appellant appealed claiming (1) convictions were against the manifest weight of the evidence and (2) the court improperly barred testimony about observed drug transactions between his father and a witness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether convictions were against the manifest weight of the evidence	State: DNA on firearm and phone data tied to Carroll supported knowing possession	Carroll: DNA could predate his 2014 conviction; phone custody/ownership not proven and searches unexplained	Court: Weight of evidence supports convictions; jury could reject Carroll’s explanations
Whether trial court abused discretion by excluding testimony that Carroll observed his father selling drugs to a witness	State: Phone evidence of searches was admissible and relevant; exclusion proper	Carroll: Testimony would explain why phone (in father’s possession) accessed drug ID sites and excuse inculpatory phone data	Court: Exclusion not an abuse—Carroll failed to proffer specifics and suffered no material prejudice; jury already disbelieved his phone-ownership claim

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for manifest-weight review)
State v. Martin, 20 Ohio App.3d 172 (Ohio App. 1983) (framework for manifest-weight analysis)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility and weight of evidence are for the trier of fact)
State v. Sage, 31 Ohio St.3d 173 (Ohio 1987) (trial court has broad discretion to admit or exclude evidence)