State v. Dent (Slip Opinion), 170 N.E.3d 816

Columbus police received complaints in Feb. 2016 about a Greenway Avenue house and conducted spot checks and surveillances (Mar. 11, Mar. 15). Detective Gauthney observed heavy short-term foot traffic consistent with a drug house.
A confidential informant purchased suspected crack cocaine from the house on Mar. 28, 2016; a no-knock warrant was obtained and executed Mar. 29.
Police seized cocaine, scales, packaging, firearms, and a kitchen video camera; the recovered video (over four hours, covering Mar. 29) depicted Dent, Walker, and Drakkar Groce cooking, weighing, bagging, exchanging money, and selling what appeared to be crack cocaine.
The video also showed familiarity among Dent, Walker, and Groce (sharing food, adjusting the camera) and conduct distinct from transient visitors, suggesting ongoing roles in the house’s drug operation.
A jury convicted Dent and Walker of engaging in a pattern of corrupt activity (R.C. 2923.32) plus drug offenses; the Tenth District reversed the RICO convictions for insufficient evidence, reasoning predicates occurred on a single day.
The Ohio Supreme Court reversed the court of appeals: it held the state presented sufficient evidence of an association-in-fact enterprise with sufficient longevity and a non‑isolated pattern of corrupt activity; Dent’s conviction reinstated and Walker’s reinstated and remanded for remaining issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence established an "enterprise" (association-in-fact) under R.C. 2923.31(C) — notably the longevity component	Surveillance, spot checks, informant buy, and video showing coordinated roles/familiarity establish purpose, relationships, and sufficient longevity to pursue the enterprise’s purpose	Video shows only one multi-hour episode; no proof of relationships or activity beyond that day	Reversed court of appeals: viewed in light most favorable to prosecution, evidence permitted a rational juror to find an enterprise with sufficient longevity
Whether predicate offenses formed a "pattern of corrupt activity" under R.C. 2923.31(E) (not isolated; not so closely related in time/place as to be a single event)	The video plus prior surveillance and buy demonstrate activity that was not isolated and allow inference the conduct extended beyond a single day	All predicate acts occurred on one day and were part of a single continuous episode; thus only one incident occurred	Reversed: a rational juror could find the incidents were not isolated and established a pattern; single‑day occurrence does not automatically preclude a pattern when other evidence shows continuity

Boyle v. United States, 556 U.S. 938 (association-in-fact enterprise requires purpose, relationships, and sufficient longevity)
Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of evidence)
Thompkins v. Ohio, 78 Ohio St.3d 380 (sufficiency review principles)
Jenks v. Ohio, 61 Ohio St.3d 259 (evidence sufficiency test in Ohio criminal cases)
Beverly v. State, 143 Ohio St.3d 258 (Ohio adopts Boyle framework for association-in-fact enterprise)
State v. Miranda, 138 Ohio St.3d 184 (pattern requires relationship and continuous activity)
State v. Schlosser, 79 Ohio St.3d 329 (RICO statutory purpose and federal model)