State v. Couch, 2016 Ohio 8452

Defendant Tyler C. Couch was indicted for illegal manufacture of drugs (hashish) near a juvenile; charge originally a first-degree felony but reduced to second-degree after court found juvenile-enhancement evidence insufficient.
Indictment alleged conduct occurred on or about June 24, 2015; Couch lived at the residence where police executed a search.
Officers found marijuana plants and processed marijuana, a book on marijuana cultivation, glass tubes and beakers, coffee filters, many butane canisters, scales, timers, chemicals, a Pyrex dish with green residue, and a pouch containing liquid hashish (25.304 g).
Couch reportedly told an officer the items were his and admitted to making hashish 10–12 times over the prior year; he also described and demonstrated the butane extraction process on video.
A jury convicted Couch; he was sentenced to four years in prison and a $7,500 fine. Couch appealed arguing insufficiency and manifest-weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove manufacturing hashish	State: physical items, admission, and video explanation support conviction	Couch: possession of components and knowledge is not proof he actually manufactured on/around charged date	Conviction upheld — evidence (direct and circumstantial) sufficient to prove manufacture on or about charged date
Date specificity of offense	State: "on or about" date is adequate; exact date unnecessary	Couch: must prove manufacture occurred June 24, 2015	Court: exact date immaterial; proof of offense on or about date sufficient
Weight of the evidence (manifest injustice claim)	State: combined evidence and admissions credible and support verdict	Couch: jury may have improperly inferred manufacture from mere possession/knowledge	Court: no manifest miscarriage of justice; verdict not against weight of evidence
Admissibility/credibility of admissions and video	State: admissions and recorded explanation are probative	Couch: contested implication between knowledge and action	Court: jury properly credited admissions and video; deference to trier of fact on credibility

State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for reviewing sufficiency of the evidence)
State v. Kirkland, 140 Ohio St.3d 73 (Ohio 2014) (deference to trier of fact on credibility and weight of evidence)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinction between sufficiency and manifest weight standards)
Tesca v. State, 108 Ohio St. 287 (Ohio 1923) (exact date/time in indictment is immaterial when nature of offense does not require exactness)
State v. Dingus, 26 Ohio App.2d 131 (Ohio Ct. App.) (proof on or about the alleged date is sufficient to support conviction)