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State v. Jones
2017 Ohio 7019
| Ohio Ct. App. | 2017
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Background

  • Store manager accepted a $100 bill from a male and female customer; bank later notified the store the bill was counterfeit. Surveillance video showed Jones at the register receiving change.
  • The female returned days later attempting to use another $100; manager recorded her license plate and alerted police. Plate traced to Dena Acklin-Byrd Jones; address matched an apartment shared with Jamal Jones.
  • Police stopped Dena’s car; Jones was a passenger. Inventory of the car produced ~1 pound of marijuana in a backpack and counterfeit bills in Dena’s purse.
  • Search warrant for Jones and Dena’s home uncovered compressed bags of marijuana in pillows and other quantities in shared areas.
  • Jones gave a recorded statement saying he and Dena sold marijuana and received counterfeit bills as payment; at trial he recanted, claiming he lied to protect Dena.
  • Jury convicted Jones of marijuana possession (R.C. 2925.11) and forgery/uttering counterfeit money (R.C. 2913.31), and the trial court imposed consecutive sentences totaling 20 months. The sole appellate claim challenged the convictions as against the manifest weight of the evidence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Were Jones’s convictions against the manifest weight of the evidence? Evidence (video, confession, recovered drugs/bills) supports guilt; jury verdict should stand. Confession was false to protect Dena; drugs and bills belonged solely to Dena. Convictions not against manifest weight; jury did not lose its way.
Did state prove constructive possession of marijuana? Drugs were found in shared home spaces (pillows, alcove) and car areas where Jones had dominion/control. Mere presence or recent residence insufficient; Jones moved in recently and lacked knowledge. Constructive possession proven by circumstantial evidence and dominion/control.
Was Jones complicit in uttering counterfeit bills (forgery/complicity)? Jones was present at transaction, accepted change, and participated in the purchase — conduct supporting aiding and abetting. Association with Dena only; she was the primary actor using the counterfeit bills. Complicity established (presence, participation, conduct before/after allowed inference of shared intent).
Did witness credibility or alternative explanations create a manifest miscarriage of justice? Witnesses (bank teller, manager, officers) and recorded statement corroborated key facts. Dena’s testimony and Jones’s trial testimony offered exculpatory alternative. Credibility resolved by jury; appellate court defers and declines to overturn.

Key Cases Cited

  • State v. Johnson, 93 Ohio St.3d 240 (Ohio 2001) (elements and standard for aiding and abetting/complicity)
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Case Details

Case Name: State v. Jones
Court Name: Ohio Court of Appeals
Date Published: Jul 31, 2017
Citation: 2017 Ohio 7019
Docket Number: CA2016-10-194
Court Abbreviation: Ohio Ct. App.