State v. Little, 2014 Ohio 4756

Police executed a search warrant at Larry Troy Little’s home after complaints of an unpermitted after‑hours bar; officers observed ~50–60 people, including three underage persons.
A controlled purchase using marked bills preceded the warrant; the marked bills were later found in a Crown Royal bag in Little’s upstairs closet.
Officers seized alcohol, a television, two fans, and $4,861 in cash (some on Little’s person, some in the closet). Little was arrested and charged with one count of selling alcohol without a permit (R.C. 4301.58(B)) and three counts of selling/furnishing alcohol to underage persons (R.C. 4301.69(A)).
At a bench trial, the court found Detective Wilcox’s testimony credible over Little’s and an underage witness’s denials, convicting Little and ordering forfeiture of the alcohol, the TV, two fans, and $4,861.
On appeal Little challenged (1) sufficiency/manifest weight of the evidence supporting the convictions and (2) the legality of the forfeiture and adequacy of forfeiture notice/procedure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency / manifest weight of evidence that Little sold/furnished alcohol and operated after‑hours bar	State: circumstantial evidence (controlled buy, marked bills, large crowd, receipts, business cards, cash stash, scene) supports convictions	Little: denied sales, underage witness denied purchases, money and alcohol were for social use	Court: Affirmed convictions — weight of evidence favors prosecution and credibility determinations were for factfinder
Forfeiture of TV, two fans, and $4,861 as proceeds/instrumentalities	State: property seized in execution of warrant may be forfeited as proceeds/instrumentalities of offenses	Little: trial court lacked authority because charging document lacked required forfeiture specification and notice	Court: Reversed forfeiture — state failed to include required forfeiture specification when property was reasonably foreseeable as forfeitable
Alternative forfeiture notice (Crim.R. 7(E)) when property not reasonably foreseeable	State: could rely on post‑filing notice under R.C. 2981.04(A)(2) if property later found forfeitable	Little: no prompt notice under Crim.R. 7(E) was given	Held: Even if property were unforeseeable, record shows no prompt notice under Crim.R. 7(E); forfeiture therefore invalid — subject‑matter jurisdiction requirement not satisfied

State v. Thompkins, 78 Ohio St.3d 380 (weight vs. sufficiency distinction and review standards)
State v. Mbodji, 129 Ohio St.3d 325 (subject‑matter jurisdiction cannot be waived; notice requirements for forfeiture)