State v. Jackson, 2016 Ohio 7637

Police executed a search warrant at Darrel Jackson’s home and seized white powder in multiple baggies, crack cocaine, scales, phones, cash, and drug paraphernalia.
Forensic testing identified measurable cocaine in several samples: one specimen 0.38 g (cocaine), one 38.2 g (cocaine), and four of five baggies in a five-baggie set totaling 137.89 g tested positive for cocaine; the fifth baggie was not tested due to lab sampling policy.
Jackson pleaded guilty to several counts, waived a jury, and proceeded to a bench trial on two counts: trafficking in cocaine and possession of cocaine, each carrying major-drug-offender specifications if the amount "equals or exceeds" 100 grams.
At trial Jackson moved for acquittal under Crim.R. 29, arguing the State must prove the weight of pure cocaine (not aggregate weight) to reach the 100-gram statutory thresholds; the trial court denied the motion and convicted him of first-degree felonies.
On appeal Jackson argued sufficiency and manifest-weight grounds, contending the State presented no evidence of the amount of pure (chemically identified) cocaine needed to elevate the offenses above fifth-degree felonies.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jackson)	Held
Whether statutory thresholds refer to total weight of the drug involved or weight of pure cocaine	The statute applies to the total aggregate weight of the drug involved (including cutting agents); weighing the whole substance is sufficient	The State must prove the weight of actual, chemically pure cocaine to meet the statutory thresholds (e.g., 100 g)	Court held statute ambiguous but, after statutory interpretation and legislative history, adopted a total-weight standard (aggregate weight of substance containing cocaine governs)
Whether evidence was sufficient to support first-degree felony findings and major-drug-offender specifications	Forensic results showing aggregate weighted samples exceeding statutory thresholds satisfied the State’s burden	Lack of proof of grams of pure cocaine meant State failed to prove elements for first-degree offenses	Court held evidence sufficient: tested samples aggregated exceeded thresholds; convictions affirmed

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for sufficiency review)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (definition of sufficiency of the evidence test)
State v. Wilson, 77 Ohio St.3d 334 (Ohio 1997) (statutory interpretation requires reading statute as a whole)
State v. Sway, 15 Ohio St.3d 112 (Ohio 1984) (criminal statutes construed strictly but consistent with statutory purpose)
Symmes Twp. Bd. of Trustees v. Smyth, 87 Ohio St.3d 549 (Ohio 2000) (conflicting appellate constructions indicate statutory ambiguity)
Garr v. Warden, Madison Corr. Inst., 126 Ohio St.3d 334 (Ohio 2010) (penalty statutes treat the substance as cocaine if it contains detectable cocaine)