State v. Meddock
2017 Ohio 4414
Ohio Ct. App.2017Background
- Charles J. Meddock and co-defendant Entler were indicted for illegal manufacture of methamphetamine (R.C. 2925.04(A)(3)) and illegal assembly/possession of chemicals for meth manufacture (R.C. 2925.041) arising from activity on/about April 5, 2015 in Pike County, Ohio.
- Anonymous tip and deputies smelled ether near a Morgantown area residence, leading them to a home on 19 North Street where Meddock and others were found.
- Appellant was hiding in a second bedroom with a one-pot meth lab; two females were also inside the home.
- A jury found Meddock guilty on both counts and he was sentenced January 27, 2016; the court merged allied offenses and proceeded on the illegal manufacture count, imposing a four-year mandatory term.
- On appeal, Meddock raises four assignments of error: improper opinion testimony, prejudicial prior-encounter evidence, denial of Crim.R. 29 motions, and cumulative error; the appellate court affirms, finding no reversible error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Officer Cottrell gave improper opinion testimony | Medduck argues Cottrell testified as an expert without disclosure | State contends lay opinion under Evid.R. 701 supported by training and scene observations | No abuse; testimony properly admitted as lay/expert under Evid.R. 701/702 depending on foundation |
| Whether the marijuana pipe evidence was improper and prejudicial | Pipe photos and related testimony were irrelevant/prejudicial | Evidence linked Meddock to the second bedroom and the lab context | No reversible error; limiting instructions supported probative value over prejudice |
| Whether the Crim.R. 29 motions should have been granted for insufficient evidence | State failed to prove Meddock knew of the lab; insufficient evidence | Evidence showed Meddock in proximity to the lab and items used in its manufacture | Sufficient evidence; trial court correctly overruled Crim.R. 29 motions |
| Whether cumulative error requires reversal | Multiple errors cumulatively deprived fair trial | No multiple errors; record shows no reversible error | Cumulative error doctrine inapplicable; judgment affirmed |
Key Cases Cited
- State v. Huff, 145 Ohio App.3d 555 (1st Dist. 2001) (404(B) and Evid.R. 701/702 framework cited; admissibility balancing)
- State v. McKee, 91 Ohio St.3d 292 (2001) (lay vs expert testimony; foundation thereof)
- State v. Rotarius, 8th Dist. Cuyahoga No. 2002-Ohio-666 (2002) (admission of other-act evidence under 404(B) with limiting instruction)
- State v. Dorsey, 1st Dist. Hamilton No. C-110623 (2012) (admissibility of other-acts evidence; strict scrutiny on probative value)
- State v. Cuffman, 3rd Dist. Crawford Nos. 3-11-01, 3-11-02, 2011-Ohio-4324 (2011) (circumstantial possession analysis; proximity evidence)