State v. Haynes, 152 N.E.3d 1217

Appellant Samuel Haynes, Sr. was charged in two consolidated cases: two counts of corrupting another with drugs (R.C. 2925.02(A)(3)) based on two separate December 2017 overdoses (victims K.D. and M.W.), and one count of aggravated possession of drugs (seized duffle bag in his van).
Haynes met both victims while they were in a treatment program; he drove them to Toledo to a heroin dealer on multiple occasions; victims purchased heroin and sometimes split it with Haynes as compensation for driving.
Both overdoses occurred at the victims’ residences after they had purchased/used heroin; Haynes was not present at either overdose and there was no testimony he injected or directly administered the drugs.
At trial the jury convicted Haynes of both corrupting-another counts and the aggravated-possession count; the court imposed a total of four years’ imprisonment (two consecutive 2‑year terms plus an 11‑month concurrent term).
On appeal Haynes challenged (1) the denial of his Crim.R. 29 motion/sufficiency of evidence for the corrupting charges, (2) manifest weight of those convictions, and (3) imposition of costs without consideration of ability to pay.
The Sixth District reversed and vacated the two corrupting‑another convictions for insufficient evidence, held the manifest‑weight claim moot, and affirmed the trial court’s imposition of prosecution costs in the aggravated‑possession case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for convictions under R.C. 2925.02(A)(3) (corrupting another with drugs) / denial of Crim.R. 29	State: Haynes’ role in obtaining heroin (driving victims to dealer) sufficed to support corrupting convictions; possession evidence supported aggravated‑possession conviction	Haynes: No evidence he administered, furnished, induced, or caused the victims to use drugs; he did not exercise dominion or control over the drugs before purchase	Reversed corrupting convictions — evidence insufficient to show Haynes administered, furnished, induced, or caused the victims’ use; Crim.R. 29 should have been granted for those counts
Manifest weight of the evidence for corrupting‑another convictions	State: jury verdict should stand based on witness testimony about joint trips and drug transactions	Haynes: convictions are against the manifest weight because testimony failed to show furnishing/inducing/causing use	Moot — sufficiency reversal disposes of manifest‑weight claim
Trial court imposing costs of prosecution without considering ability to pay (aggravated‑possession case)	Haynes: court erred by assessing costs without addressing his present/future ability to pay	State: R.C. 2947.23(A)(1)(a) requires the court to include costs of prosecution in the sentence; ability to pay is not a prerequisite	Affirmed for CR0351 — costs of prosecution properly imposed (statutorily mandatory)

State v. Brinkley, 824 N.E.2d 959 (Ohio 2005) (Crim.R. 29 sufficiency challenge standard)
State v. Tenace, 847 N.E.2d 386 (Ohio 2006) (Crim.R. 29 denial governed by sufficiency-of-evidence standard)
State v. Smith, 684 N.E.2d 668 (Ohio 1997) (sufficiency review asks if any rational trier of fact could find elements proved beyond reasonable doubt)
State v. Were, 890 N.E.2d 263 (Ohio 2008) (appellate court will not weigh witness credibility on sufficiency review)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (distinguishes sufficiency and manifest‑weight standards; courts sit as a "thirteenth juror" on manifest weight)
State v. Collins, 41 N.E.3d 899 (Ohio 2015) (appellate standard for modifying financial sanctions requires clear and convincing evidence)