State v. Evans-Goode
2016 Ohio 5361
Ohio Ct. App.2016Background
- Susan Evans-Goode was indicted for (1) illegal manufacture of methamphetamine (R.C. 2925.04) and (2) illegal assembly/possession of chemicals to manufacture methamphetamine (R.C. 2925.041) arising from a January 2015 search of a residence where she lived and her vehicle.
- Officers observed occupants with foil and smoke, saw items in plain view (Drano, tubing), obtained a warrant, and found an active one‑pot meth lab in Appellant’s vehicle plus numerous precursors and paraphernalia in the residence and trash.
- Evidence included NPLEx pharmacy records showing pseudoephedrine purchases, a co‑defendant’s testimony that Evans‑Goode helped cook meth and bought precursors, BCI lab confirmation that items from the one‑pot contained methamphetamine, and law enforcement testimony identifying chemicals and equipment.
- Appellant was convicted by a jury of both counts and sentenced to consecutive prison terms totaling eleven years.
- On appeal she argued (1) insufficient evidence for the assembly/possession conviction and (2) violation of double jeopardy / failure to merge allied offenses for sentencing.
- The Fourth District affirmed, holding the evidence supported both convictions and the offenses did not merge because they were committed separately or with separate animus.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Evans‑Goode) | Held |
|---|---|---|---|
| Sufficiency of evidence for illegal assembly/possession and manufacture | Evidence (NPLEx records, co‑defendant testimony, BCI confirmation of meth from one‑pot, police identification of precursors and scales with appellant’s name) supports knowing possession/assembly and manufacturing | State failed to identify/test chemicals (e.g., Coleman fuel, Drano, lithium) and failed to prove appellant possessed those chemicals | Affirmed: viewed in prosecution’s favor, a rational juror could find elements beyond reasonable doubt |
| Merger / allied‑offenses (R.C. 2941.25; Double Jeopardy) | Conduct involved separate acts over time (pseudoephedrine purchases before and after cook, extra precursors beyond single cook, active one‑pot in vehicle) showing separate conduct/animus | Offenses arose from the same occasion/encounter and thus should merge | Affirmed: offenses not allied; committed separately or with separate animus, so no merger required |
Key Cases Cited
- Thompkins v. Ohio, 78 Ohio St.3d 380 (sufficiency review; due process standard)
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- Jenks v. Ohio, 61 Ohio St.3d 259 (framework for reviewing sufficiency of the evidence)
- Ruff v. Ohio, 143 Ohio St.3d 114 (test for allied offenses under R.C. 2941.25: conduct, animus, import)
- North Carolina v. Pearce, 395 U.S. 711 (double jeopardy prohibits multiple punishments for the same offense)