State v. Little, 2023 Ohio 4098

Three controlled buys (Feb 26, Mar 5, Mar 23, 2021) in which a confidential informant (C.I.) purchased methamphetamine allegedly arranged by Angel Little; video/audio recorded and drugs tested positive for meth.
June 23, 2021 traffic stop of an SUV Little was driving during a drug-task-force interdiction; a canine alerted and officers found ~55.22 g methamphetamine in a sunglasses case under the vehicle hood.
Portage County grand juries indicted Little: three counts of aggravated trafficking (2022 case) and aggravated trafficking and aggravated possession tied to the hood stash (2021 case).
Trial court denied Little’s pretrial motion to suppress evidence from the traffic stop; the two indictments were joined for trial; Little was convicted by jury on four counts and sentenced to an aggregate 5 to 6.5 years and $7,500 fine.
Little appealed raising three assignments: (1) suppression error (unconstitutional stop/detention), (2) insufficiency of evidence, and (3) improper joinder/failure to sever.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Motion to suppress (traffic stop & detention)	Stop/detention were lawful: officers had observed suspected hand-to-hand drug activity and traffic violations; canine sniff lawful	Stop was pretextual and detention impermissibly prolonged for a K-9 sniff	Denial affirmed — stop supported by reasonable suspicion and probable cause; detention and canine sniff lawful (no artificial prolongation shown)
2. Sufficiency of evidence for trafficking and possession	C.I. testimony, recorded buys, identifications, and BCI drug testing sufficiently proved trafficking and constructive possession	Evidence insufficient: no direct proof Little committed the buys or possessed the hood stash	Convictions affirmed — evidence, if believed, was legally sufficient for three trafficking counts and one aggravated possession count
3. Joinder / severance of two indictments	Joinder proper; evidence simple and distinct so no prejudice	Joinder prejudiced Little; trial of unrelated matters together warranted severance	No plain error — joinder (joinder test) met; defendant failed to preserve a fuller severance argument and showed no manifest prejudice

Delaware v. Prouse, 440 U.S. 648 (vehicle stop is a Fourth Amendment seizure)
Illinois v. Caballes, 543 U.S. 405 (exterior canine sniff during lawful traffic stop is not a search)
State v. Burnside, 797 N.E.2d 71 (Ohio 2003) (standard of review for suppression mixed question of law and fact)
State v. Mays, 894 N.E.2d 1204 (Ohio 2008) (reasonable, articulable suspicion justifies investigatory stop)
State v. Batchili, 865 N.E.2d 1282 (Ohio 2007) (duration of traffic stop and K-9 sniff rules; delay permissible if supported by suspicion)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (definition of sufficiency of the evidence)
State v. Jenks, 574 N.E.2d 492 (Ohio 1991) (standard for sufficiency review: evidence viewed in light most favorable to prosecution)
State v. Johnson, 754 N.E.2d 796 (Ohio 2001) (aiding/abetting/complicity principles)
State v. Gordon, 98 N.E.3d 251 (Ohio 2018) (law favors joinder of offenses)
State v. Roberts, 405 N.E.2d 247 (Ohio 1980) (joinder/joinder-test; jury can segregate proof when evidence is simple and direct)
State v. Long, 372 N.E.2d 804 (Ohio 1978) (plain-error rule standard)