State v. Dunn, 2017 Ohio 8618

Officer Godwin stopped Danny L. Dunn after running his plate and learning his license was under a drug suspension.
While verifying Dunn’s driving privileges, a canine unit alerted to Dunn’s vehicle; the officer searched the car.
Officer Godwin found a pill bottle in the center console that smelled of raw marijuana and contained green residue. He testified he is trained to identify marijuana by sight and smell.
Dunn was Mirandized, then admitted the pill bottle was his and that he had used it to store marijuana in the past, saying it was "old" and he had not cleaned the car.
Dunn was charged with and convicted of possessing marijuana drug paraphernalia under R.C. 2925.141(C); the trial court fined him and suspended his license, and the conviction was stayed pending appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Dunn knowingly possessed a pill bottle intended for use as marijuana paraphernalia	State: admission plus officer’s observation/smell of residue proves the bottle was drug paraphernalia and Dunn knowingly used/possessed it	Dunn: he only admitted past use; no evidence of present intent to use; residue was not lab-tested	Court: Evidence sufficient. Officer’s training, immediate smell/observations, plus Dunn’s admission satisfied elements beyond reasonable doubt

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for reviewing criminal convictions and distinction between sufficiency and manifest weight)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sufficiency test: evidence viewed in light most favorable to prosecution)