State v. Porter, 2019 Ohio 4482

Kettering officer ran a random license-plate/registration check on a pickup and stopped it after learning registration had expired; Porter was the sole occupant.
LEADS check showed Porter had no Ohio driving privileges and an active probation-violation arrest warrant; officers removed, handcuffed, and placed him in a cruiser.
Officer Wolf observed the butt of a handgun protruding from the driver-door pocket; the handgun was loaded and secured.
A backpack in the passenger area contained a black jacket, ski mask, wig, gloves, and a brown jar with acidic liquid; bolt cutters and binoculars were found under the passenger seat. Porter admitted the jar was his and that he used the bolt cutters for work.
Porter was indicted for having weapons while under disability (prior felony of violence), improper handling of a firearm in a motor vehicle, and carrying a concealed weapon; photos of the additional items were admitted under Evid.R. 404(B).
Jury convicted on all counts; trial court sentenced to concurrent terms (aggregate 24 months). Porter appealed, challenging (1) admission of the photos/other-items evidence, (2) the traffic stop’s legality, and (3) the sufficiency of evidence (Crim.R. 29) regarding knowledge/possession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of photos/other-items (Evid.R. 404(B)/403)	Photos admissible to show identity, absence of mistake, opportunity, and that Porter regularly used the vehicle (hence knew of the gun).	Photos were irrelevant and unfairly prejudicial because they suggested other criminal activity and tainted jury perception.	Admitted: satisfied Williams three-part test; probative value (knowledge/identity/absence of mistake) outweighed minimal prejudice; limiting instructions given.
Legality of traffic stop (Fourth Amendment)	Stop valid: officer acted on a random in-cruiser registration check showing expired registration.	Stop violated Fourth Amendment; evidence should be suppressed.	Waiver: no suppression motion filed (only plain-error review). In any event random license-plate/registration checks are permissible; no plain error.
Sufficiency of evidence for knowledge/possession (Crim.R. 29)	Circumstantial evidence (gun location in driver door, Porter as primary driver, personal items in vehicle, loaded operable gun) suffices to prove knowledge and constructive possession.	No direct evidence (fingerprints); state failed to prove Porter knew of or possessed the gun.	Affirmed: viewing evidence in prosecution’s favor, a rational juror could find knowledge and constructive possession beyond a reasonable doubt.

State v. Williams, 983 N.E.2d 1278 (Ohio 2012) (sets three-part test for admitting other-acts evidence under Evid.R. 404(B)).
State v. Morales, 513 N.E.2d 267 (Ohio 1987) (Evid.R. 403 balancing — probative value must be minimal and prejudice great to exclude).
State v. Perez, 920 N.E.2d 104 (Ohio 2009) (other-acts admission reviewed for abuse of discretion and material prejudice).
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (articulable-suspicion standard for investigative stops).
Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (discussion of seizure under Fourth Amendment).
State v. Leveck, 962 N.E.2d 316 (Ohio App. 2011) (random, in-cruiser license-plate checks do not implicate the Fourth Amendment).
State v. Jenks, 574 N.E.2d 492 (Ohio 1991) (standard for sufficiency review: whether any rational trier of fact could find elements proven beyond a reasonable doubt).
State v. Lott, 555 N.E.2d 293 (Ohio 1990) (circumstantial evidence may sustain a conviction).