State v. Griffin
2013 Ohio 3309
Ohio Ct. App.2013Background
- December 23–24, 2011, Barrow and a juvenile passenger, Henderson, traveled with Griffin after Barrow sought a ride for drugs.
- Crack cocaine (23.86 grams) was found inside a hair gel container in a jacket Griffin owned, later recovered during vehicle search.
- The stop occurred on U.S. 23 near Lucasville for a non-functioning rear tag light and no front plate; Griffin was the driver.
- Griffin was arrested for OVI after a .044 BAC and field and breath tests.
- Barrow and Henderson were in the car; marijuana residue was found on Henderson, prompting a full vehicle search.
- Indictment charged five counts including Trafficking in Drugs Within the Vicinity of a Juvenile, Possession of Crack Cocaine, OVI, Possession of Marijuana, and Display of License Plates; the State dismissed one count and the jury convicted on others.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency and manifest weight of the evidence. | Griffin argues the evidence is insufficient and weighs against guilt. | Griffin contends the verdict conflicts with the evidence and is against the weight. | Convictions affirmed; evidence sufficient and not against the weight. |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (sufficiency/weight standards for review; means of weighing evidence)
- State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (judicial standard for circumstantial evidence)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (federal standard for sufficiency of evidence)
- State v. Eley, 56 Ohio St.2d 169 (Ohio 1978) (syllabus on sufficiency/weight considerations)
- State v. Hill, 75 Ohio St.3d 195 (Ohio 1996) (guidance on appellate review of evidence in light most favorable to prosecution)