State v. Henderson, 2014 Ohio 4601

At 2:00 a.m., a deputy stopped a white Chevy Impala for expired registration; David Henderson was the driver and had a suspended license.
During an inventory search after the vehicle was towed, officers found a loaded 9mm handgun in the unlocked glove compartment; Henderson was arrested.
Henderson denied knowledge of the gun; he said he borrowed the car from a friend and could not identify the owner or the friend. The car was registered to Gwendolyn Acker.
No fingerprints on the gun matched Henderson, but touch‑DNA testing indicated Henderson’s DNA was present on the weapon.
Henderson was indicted on Having Weapons Under Disability (prior drug felony) and Improper Handling of a Firearm in a Motor Vehicle; a jury convicted him only of the weapons‑under‑disability charge and acquitted on the other charge.
He appealed, arguing Batson error (prosecutor’s peremptory strike of an African‑American venire member), inconsistent verdicts, insufficiency and manifest‑weight problems with the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the prosecutor’s peremptory strike violated Batson	State: struck juror for race‑neutral reason (timid/reticent, likely follower)	Henderson: second African‑American struck; raises Batson challenge	Court: trial court credited race‑neutral reason; no Batson error
Whether inconsistent verdicts (guilty on one count, acquitted on another) require reversal	State: verdicts need not be consistent across different counts	Henderson: conviction inconsistent with acquittal on related count	Court: inconsistent verdicts across different counts are permissible; no reversal
Whether evidence was sufficient to convict of Having Weapons Under Disability	State: DNA on gun + Henderson was sole occupant and driver supports constructive possession	Henderson: no fingerprints, not owner, not observed with gun—insufficient to prove possession	Court: evidence (DNA, exclusive control of vehicle) sufficient for constructive possession; conviction stands
Whether conviction is against the manifest weight of the evidence	State: credibility and inferences supported verdict	Henderson: jury lost its way given alternatives	Court: deference to jury credibility findings; not against manifest weight

Batson v. Kentucky, 476 U.S. 79 (1986) (established three‑step test for race‑based peremptory challenges)
Powers v. Ohio, 499 U.S. 400 (1991) (Batson extended to defendants challenging strikes of jurors of a different race)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for reviewing sufficiency of the evidence)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency and manifest‑weight review)
State v. Lovejoy, 79 Ohio St.3d 440 (1997) (inconsistent verdicts across different counts do not require reversal)
State v. Wolery, 46 Ohio St.2d 316 (1976) (constructive possession defined as dominion and control)