State v. Johnson, 128 Ohio St. 3d 107

Johnson was convicted of having weapons while under disability under R.C. 2923.13(A)(3) based on prior drug offenses.
The indictment tracked the statute, alleging he knowingly possessed a firearm while under a disability due to prior drug convictions.
Trial court instructed jurors there was a stipulation of the listed prior convictions but did not require any mens rea regarding those prior convictions.
On appeal, the Eighth District held recklessness as to the prior conviction was required.
The Supreme Court held that the state need not prove a culpable mental state for the element of being under indictment or convicted of a drug offense for this statute.
The decision clarifies how R.C. 2901.21(B) interacts with multielement offenses and the WUD provision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether recklessness is required for prior convictions under R.C. 2923.13(A)(3)	Johnson argued the state must prove recklessness about the prior drug conviction.	State contended no additional mens rea is required for the prior-conviction element.	No; recklessness not required for the prior-conviction element.

State v. Maxwell, 95 Ohio St.3d 254 (2002-Ohio-2121) (establishes Maxwell two-part test for missing mens rea under 2901.21(B))
State v. Adams, 62 Ohio St.2d 151 (1980) (recklessness required where statute silent on mens rea and not strict liability)
State v. Wac, 68 Ohio St.2d 84 (1981) (illustrates strict liability analysis when some provisions lack mens rea)
State v. Clay, 120 Ohio St.3d 528 (2008) (controls WUD analysis; addressed recklessness/knowledge in WUD)