State v. Fultz, 2016 Ohio 1486

Police went to appellant Crystal Fultz’s aunt’s home after a complaint; officers encountered Fultz in a small back bedroom where she had been lying with her 11‑year‑old daughter.
Officers observed drug residue on a tin plate and obtained the aunt’s consent to search the bedroom and house.
Search uncovered: 38 tablets containing heroin, 78 alprazolam tablets, a small cut straw (in a purse), and hypodermic needles/syringe; pills were found in a pillowcase where Fultz had been lying.
No drugs were found on Fultz’s person; she denied ownership of the purse, pills, and paraphernalia but admitted a drug problem and prior use of alprazolam and snorting heroin.
At trial, officers testified Fultz tried to grab the purse and later claimed it as hers during booking; only three people were present in the house.
Jury convicted Fultz of possession of heroin, possession of drugs (alprazolam), and possession of drug paraphernalia (straw); acquitted on possession of a syringe.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove knowing possession of heroin and alprazolam	State: circumstantial evidence (drugs in pillow where Fultz lay, small room, only three people there, accessibility) supports conviction	Fultz: mere presence in a room with drugs insufficient; denied knowledge/ownership of items	Held: State presented sufficient evidence to convict (constructive possession shown)
Manifest weight: whether verdict was against manifest weight of evidence	State: jurors could believe officer testimony and infer knowledge from conduct and accessibility	Fultz: jury should have credited her testimony denying possession and ownership of purse and items	Held: Convictions not against manifest weight; jury credibility determinations upheld

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for granting a new trial on manifest-weight grounds)
State v. Logan, 60 Ohio St.2d 126 (Ohio 1979) (a defendant’s mental state may be inferred from surrounding circumstances)