State v. Mayweather, 2018 Ohio 1686

Jerez S. Mayweather was indicted on three fifth-degree counts of trafficking in heroin based on three controlled buys in December 2016 using a confidential informant (CI).
The CI arranged buys by phone, was searched and provided prerecorded buy money, returned drugs to detectives after purchases, and identified Mayweather as “Capo.” Laboratory testing confirmed heroin.
Surveillance officers observed vehicles and scenes associated with the buys but did not always directly witness the hand-to-hand exchanges; some officers lost sight at times.
A jury convicted Mayweather on all three counts; the trial court sentenced him to consecutive one-year terms (aggregate three years).
Appellate counsel filed an Anders brief; Mayweather filed pro se claims challenging sufficiency/manifest weight, prosecutorial suppression (Brady), ineffective assistance, and the imposition of consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence	Evidence (CI ID, prerecorded money, returned drugs, lab tests) proves trafficking beyond a reasonable doubt	Testimony inconsistencies and limited direct surveillance undercut proof	Convictions upheld; evidence sufficient and not against manifest weight
Manifest weight of the evidence	CI credibility and corroboration support verdict	CI inconsistencies and surveillance gaps show jury lost its way	Rejected; jury was best judge of credibility; no miscarriage of justice
Prosecutorial suppression (Brady) / discovery	No withheld material evidence; CI’s vague statements about other buys not material	Prosecutor suppressed exculpatory/impeaching information; counsel failed to seek recess	Rejected; CI’s vague remarks were not material Brady evidence; no misconduct or ineffective assistance found
Consecutive sentencing under R.C. 2929.14(C)(4)	Court properly found consecutive terms necessary and not disproportionate, and identified statutory factors	Appellant argued sentences should not be consecutive	Partially reversed: trial court made required findings in written entry but did not make them on the record at the sentencing hearing; remanded for resentencing (limited purpose)

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedure when counsel seeks to withdraw on appeal as frivolous)
Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecutor must disclose materially exculpatory evidence)
Bagley v. United States, 473 U.S. 667 (U.S. 1985) (Brady materiality standard as reasonable probability of different result)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sufficiency standard for criminal convictions)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest-weight review standard)
State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (requirements for making and recording statutory findings to impose consecutive sentences)
State v. Johnston, 39 Ohio St.3d 48 (Ohio 1988) (disclosure obligations under Brady / Crim.R. 16)