State v. Groce (Slip Opinion), 170 N.E.3d 813

Groce was tried jointly with Alvin Dent Jr. and William Walker Jr.; a jury convicted all three of engaging in a pattern of corrupt activity (R.C. 2923.32) and related drug and firearm offenses.
The Tenth District Court of Appeals reversed Groce’s R.C. 2923.32 conviction for insufficiency of the evidence.
The state appealed to the Ohio Supreme Court; Groce cross‑appealed on a related legal proposition about the required duration of criminal activity.
The Ohio Supreme Court considered the same trial record it reviewed in State v. Dent and framed the question as whether the evidence established an enterprise (association‑in‑fact) and a pattern of corrupt activity over a sufficient time period.
The Court applied the sufficiency‑of‑the‑evidence standard (viewing the evidence in the light most favorable to the prosecution) and relied on surveillance and testimonial evidence showing ongoing, coordinated drug activity at the Greenway Avenue house.
The Supreme Court reversed the Tenth District, holding the evidence supported both an association‑in‑fact enterprise and a pattern of corrupt activity, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence established an enterprise (association‑in‑fact) under R.C. 2923.31(C)	State: Surveillance and interactions showed a functioning organization with a shared purpose to manufacture and sell cocaine; not strangers but associates	Groce: Insufficient proof of an ongoing organized enterprise or relationship beyond isolated contacts	Held: Evidence permitted a rational juror to find a purpose and relationship and an association‑in‑fact enterprise with sufficient longevity
Whether the criminal acts formed a "pattern of corrupt activity" under R.C. 2923.31(E) (timeframe requirement)	State: Video and other evidence showed repeated, related illegal conduct—not isolated or a single transaction—over time, satisfying the pattern requirement	Groce: Activity was too isolated or too closely connected to be treated as multiple acts constituting a pattern; required a longer continuous period	Held: Evidence showed corrupt activity that was neither isolated nor so temporally tight as to be a single offense; pattern requirement satisfied

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (describes standard for reviewing sufficiency of evidence)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sets out the Jackson v. Virginia sufficiency test adopted in Ohio)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of the evidence standard requiring proof beyond a reasonable doubt by a rational trier of fact)
In re J.V., 134 Ohio St.3d 1 (Ohio 2012) (confirms de novo review for legal sufficiency questions)
State v. Smith, 80 Ohio St.3d 89 (Ohio 1997) (addresses limits and application of Jenks/Jackson sufficiency principles)