State v. Corson, 2015 Ohio 5332

Corson was indicted on one count of possession of cocaine in Pickaway County for events occurring during a February 29, 2012 traffic stop.
During the stop, the odor of marijuana was detected; the passenger, Zanisha Marshall, had cocaine concealed in her vagina.
The cocaine, amounting to 2.73 grams of crack cocaine, was found and tested by the Ohio State Highway Patrol Crime Lab.
Corson and Marshall were charged; both were jailed and indicted on related drug offenses.
Corson was arraigned December 2, 2014, pleaded not guilty, and the jury convicted him of possession of cocaine.
The trial court sentenced Corson to ten months in prison, consecutive to another sentence, delaying his release date.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction was against the manifest weight of the evidence	Corson contends no actual possession or constructive possession by him was shown.	State argues the evidence shows dominion or control by Corson over the cocaine via possession or constructive possession.	No manifest weight; rational basis supports the verdict.

Eastley v. Volkman, 132 Ohio St.3d 328 (Ohio Supreme Court 2012) (standard for manifest weight review)
State v. Wickersham, 2015-Ohio-2756 (4th Dist. Meigs 2015) (deference to credibility and weight in manifest weight review)
State v. Criswell, 2014-Ohio-3941 (4th Dist. Scioto 2014) (possession may be actual or constructive; circumstantial evidence acceptable)
State v. Moon, 2009-Ohio-4830 (4th Dist. Adams 2009) (constructive possession may be inferred via dominion and control)
State v. Brown, 2009-Ohio-5390 (4th Dist. Athens 2009) (driver's dominion over vehicle supports possession inference)
State v. Hankerson, 70 Ohio St.2d 87 (Ohio Supreme Court 1982) (constructive possession requires knowledge or presence of object)
Kingsland v. State, 177 Ohio App.3d 655 (4th Dist. Ohio 2008) (joint constructive possession possible)