State v. McClain, 2018 Ohio 538

Trooper Justin Ross stopped Matthew McClain after reports of unsafe driving and observing the vehicle veer left of center and recent-looking damage.
Ross observed glassy, dilated pupils and hand movements; McClain disobeyed instructions to keep hands on the wheel.
Ross administered standardized field sobriety tests and observed multiple clues of impairment, then arrested McClain for OVI (R.C. 4511.19(A)(1)(a)).
Troopers found marijuana and paraphernalia in McClain’s car; McClain admitted past marijuana use and that he takes Adderall.
No evidence of alcohol use; urine sample was insufficient for drug testing.
After a bench trial, the municipal court convicted McClain; he appealed arguing the State failed to prove the nexus between his impairment and a drug of abuse.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that impairment was caused by a drug of abuse under R.C. 4511.19(A)(1)(a)	State: Observed physiological signs of impairment + admission of Adderall use + marijuana found in vehicle suffice to prove impairment from a drug of abuse	McClain: No proof that marijuana or Adderall caused impairment at the time; State presented no evidence linking his signs to those substances	Affirmed: Viewing evidence in prosecution’s favor, a rational trier of fact could find the nexus — conviction supported; not against manifest weight

Eskridge v. State, 38 Ohio St.3d 56 (Ohio 1988) (discussed standard for reviewing sufficiency of evidence)
Thompkins v. Ohio, 78 Ohio St.3d 380 (Ohio 1997) (standard for reviewing weight of the evidence)
Jenks v. Ohio, 61 Ohio St.3d 259 (Ohio 1991) (sufficiency review: evidence viewed in light most favorable to prosecution)
Otten v. State, 33 Ohio App.3d 339 (Ohio Ct. App. 1986) (weight-of-the-evidence standard and when reversal is required)
State v. Richardson, 150 Ohio St.3d 554 (Ohio 2016) (discusses need for evidence tying impairment to a specific intoxicant)