State v. Delrossi, 2014 Ohio 4457

Police stopped a vehicle connected to meth manufacture; items found linked to meth production at 92 Willard; search of 92 Willard led to discovery of methamphetamine and lab precursors; occupants of 92 Willard, including Delrossi, were arrested; Indictment charged Delrossi with illegal manufacture and possession of chemicals for meth manufacture; State proceeded to jury trial and Delrossi convicted on both counts but allied offenses doctrine led to sentencing on one count.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict on 10/28/2012	Delrossi possessed or manufactured meth precursors on that date	No evidence she possessed/assembled chemicals or manufactured meth on that date	Insufficient evidence; conviction reversed
Jury instruction and implications on complicity claim	State sought complicity instruction to support conviction	Court denied the complicity instruction	Moot due to lack of sufficient evidence on main counts
Indictment date sufficiency near date	Date in indictment supported by evidence of near-date activity	Evidence did not show activity on or near Oct 28, 2012	Dates near Oct 28 not proven; insufficiency sustained

State v. Slevin, 9th Dist. Summit No. 25956 (2012-Ohio-2043) (sufficiency review; de novo; reasonable doubt standard)
State v. Williams, 9th Dist. Summit No. 24731 (2009-Ohio-6955) (standard for sufficiency; credibility not assessed on appeal)
State v. Jenks, 61 Ohio St.3d 259 (1991) (scintilla test; XYZ standard for reviewing evidence on appeal)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (establishes standard for whether evidence proves guilt beyond reasonable doubt)
State v. Forney, 9th Dist. Summit No. 24361 (2009-Ohio-2999) (date specificity allowed near indicted date; non-essential elements)