State v. Price-Tuggle, 2026-Ohio-1027

During a May 2021 traffic stop of a rental SUV with Michigan plates, Trooper Lewis found heroin, fentanyl, and cocaine concealed on codefendant James. 1
Appellant Jalisa Price-Tuggle was the backseat passenger and was indicted on trafficking, possession, and criminal-tools counts. 2
Before trial, appellant filed but then withdrew her motion to suppress, and James also withdrew hers. 3
At trial, Lewis testified to traffic violations, inconsistent travel stories, lack of luggage, appellant's remarks about checking the car, and James's concealed drugs. 4
James testified appellant knew of the drug run and was involved, while appellant denied knowledge and claimed she merely agreed to drive. 5
The jury convicted appellant on all counts, the court merged the drug counts, imposed an indefinite 4-to-6-year sentence plus 12 months concurrent, and this appeal followed. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for drug convictions 7	Price-Tuggle says the State proved only proximity.	State says circumstantial evidence showed constructive possession and trafficking.	Evidence was sufficient. 8
Manifest weight of the evidence 9	Price-Tuggle says James was unreliable and evidence favored acquittal.	State says the jury could credit James and the other evidence.	Convictions were not against the manifest weight. 10
Withdrawal of suppression motion as ineffective assistance 11	Price-Tuggle says counsel should have pursued suppression.	State says the stop and search were lawful, so suppression would fail.	No deficient performance or prejudice. 12
Failure to call Robinson as witness 13	Price-Tuggle says Robinson would have supported the defense.	State says the claim relies on extra-record evidence and speculation.	Claim not reviewable on direct appeal. 14
Other trial-counsel errors 15	Price-Tuggle says counsel mishandled video, cross-examination, and witnesses.	State says these were strategic choices and no prejudice was shown.	No ineffective assistance. 16

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (sufficiency and manifest-weight standards 17)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review asks whether any rational trier of fact could find guilt beyond a reasonable doubt 18)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (circumstantial and direct evidence have the same probative value 19)
State v. Hankerson, 70 Ohio St.2d 87 (Ohio 1982) (constructive possession requires dominion, control, and consciousness of the object's presence 20)
State v. Jordan, 89 Ohio St.3d 488 (Ohio 2000) (knowledge of specific controlled-substance characteristics is not required 21)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective-assistance requires deficient performance and prejudice 22)
State v. Cooperrider, 4 Ohio St.3d 226 (Ohio 1983) (ineffective-assistance claims based on facts outside the record are not resolved on direct appeal 23)
Dayton v. Erickson, 76 Ohio St.3d 3 (Ohio 1996) (a traffic stop based on probable cause of a violation is reasonable despite ulterior motive 24)
State v. Whren v. United States, 517 U.S. 806 (U.S. 1996) (probable-cause traffic stops are constitutionally reasonable 25)