State v. Mathis, 2019 Ohio 2289

On April 3, 2016, police stopped a rental car; Mathis was a passenger and officers detected burnt and raw marijuana odors.
Mathis was handcuffed, searched, and placed in a patrol cruiser; officers later located a large bag containing eight similarly weighted, separately packaged baggies of marijuana hidden in his underwear (total 33.79 g).
Officers found large wads of cash in Mathis’s pockets (around $3,018 by evidence notation); officers and a narcotics sergeant testified packaging and cash were consistent with trafficking, not personal use.
Mathis attempted to flee after being told he would be arrested for trafficking; a struggle ensued and officers restrained him.
Mathis was indicted for trafficking, possessing criminal tools (dismissed), resisting arrest, and possession; a suppression motion limited some statements but allowed the marijuana under inevitable discovery.
A jury convicted Mathis of Trafficking in Marijuana and Resisting Arrest; he was sentenced to concurrent terms and appealed challenging sufficiency and weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to support Trafficking in Marijuana (R.C. 2925.03(A)(2))	Packaging (one large bag containing multiple similarly weighted small baggies), quantity (~33.79 g), and large cash sum indicate intent to distribute	The quantity/packaging could be for personal use; girlfriend testified Mathis routinely bought packaged marijuana and she gave him cash for rent	Affirmed — evidence (packaging, weights, cash, officer testimony, rental car) supported conviction; jury credibility determinations upheld
Whether resisting arrest conviction was supported where defendant was handcuffed/placed in cruiser before attempt to flee	Officers had probable cause and were in process of effecting an arrest; resistance occurred during arrest process	Mathis argued he was already in custody (handcuffed in cruiser) and believed arrest unlawful, so resistance did not meet offense elements	Affirmed — resistance occurred during the arrest process; officers had probable cause, so the arrest was lawful for purposes of R.C. 2921.33(A)

State v. Jenks, 61 Ohio St.3d 259 (sufficiency standard; reviewing evidence in light most favorable to prosecution)
Jackson v. Virginia, 443 U.S. 307 (1979) (constitutional sufficiency standard for criminal convictions)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency and weight of the evidence)
State v. Wilson, 113 Ohio St.3d 382 (2007) (weight-of-evidence principles)
State v. Bay, 130 Ohio App.3d 772 (arrest is a process; resisting during arrest process can support conviction)
State v. Huffman, 38 Ohio App.3d 84 (handcuffed defendant who then resisted may be convicted of resisting arrest)