State v. Lynch, 2012 Ohio 2521

METRICH agents conducted controlled heroin buys at Lynch's residence in 2010 with video/audio records.
A search warrant on August 6, 2010 revealed drug paraphernalia and a rifle; Lynch admitted purchasing heroin and selling balloons that week.
Lynch was indicted in February 2011 on weapons, trafficking, and EPCA charges.
He pled guilty to four counts; a bench trial determined the EPCA count.
The trial court sentenced Lynch to three years; Lynch appeals raising three assignments of error.
The appellate court affirms four counts but reverses and remands the EPCA conviction for lack of enterprise evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the EPCA conviction satisfied the $500 contraband value threshold.	State argues heroin value exceeded $500.	Lynch contends insufficient evidence of value.	Value exceeded $500; EPCA conviction upheld on this point.
Whether there was a separate enterprise to support EPCA under R.C. 2923.32(A)(1).	State asserts existence of an ongoing enterprise.	Lynch argues no distinct enterprise beyond trafficking.	EPCA conviction reversed for lack of a separate enterprise.
Whether the EPCA conviction was against the weight of the evidence.	Not explicitly stated beyond sufficiency challenges.	Challenged overall weight given lack of enterprise.	Moot due to reversal on enterprise grounds.

Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard of review for sufficiency of evidence in criminal cases)
State v. Schlosser, 79 Ohio St.3d 329 (Ohio 1997) (RICO enterprise element; separation from pattern of activity)
State v. Boyle, 556 U.S. 938 (U.S. 2009) (enterprise need not be technically separate but may coalesce with pattern)
United States v. Turkette, 452 U.S. 576 (U.S. 1981) (enterprise element distinct from pattern of racketeering)
State v. Scott, 2007-Ohio-303 (Ohio- Morgan App. 2007) (requires evidence of ongoing enterprise separate from pattern)