State v. Radford, 2017 Ohio 8189

In March 2015 Clark County deputies investigated suspected drug trafficking at the Relax Inn, focusing on Room 125, which was rented to Arthur Radford.
Deputies observed Radford repeatedly entering/exiting Room 125 and interacting with visitors; two visitors were intercepted who had drugs and one admitted purchasing drugs from someone in Room 125.
During a patdown at arrest, deputies found 10.64 grams of marijuana and $1,200 on Radford; a search warrant later uncovered in Room 125 digital scales with white residue, marijuana, crack cocaine, a crack pipe, 3.22 grams of heroin, a .380 semiautomatic handgun in the air conditioner, ammunition, men’s clothing, receipts bearing Radford’s name, and a large TV.
Radford’s vehicle search yielded 1.48 grams of crack and an auto-parts store receipt with his name.
Radford was indicted on counts including trafficking in cocaine and heroin and having weapons under disability; jury convicted on all counts and court merged possession counts into the trafficking counts for sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to prove constructive possession of drugs	Circumstantial evidence (leased room, receipts with Radford’s name, male clothing, visitors buying drugs, Radford entering/exiting, his instruction to close the door) establishes dominion and control	Items not in Radford’s immediate control; mere access to room insufficient to prove possession	Sufficient: jury could find constructive possession based on surrounding facts and inferences
Sufficiency to prove trafficking (cocaine and heroin)	Cash in small denominations, digital scales, drugs in multiple locations, and other indicia (large TV, visitors) support intent to distribute	State failed to prove these items belonged to Radford or that he intended distribution	Sufficient: evidence permitted reasonable inference of trafficking
Weapons under disability (possession of firearm)	Operable handgun found in room where Radford exercised control; parties stipulated Radford was under disability	Gun not on his person; possession not proved beyond constructive-possession inference	Sufficient: constructive possession established by room control and other indicia
Manifest-weight challenge	Jury reasonably credited deputies and other evidence; record not so contrary to verdict as to require new trial	Verdict was against weight because proof of ownership/possession was circumstantial	Overruled: appellate court defers to jury credibility determinations; not an exceptional case warranting new trial

State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review: evidence must permit a rational trier of fact to find each element beyond a reasonable doubt)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest-weight standards)
State v. Martin, 20 Ohio App.3d 172 (1984) (standard for manifest-weight review; new trial only in exceptional cases)
State v. Haynes, 25 Ohio St.2d 264 (1971) (leasing premises alone insufficient to prove possession)
State v. Pilgrim, 184 Ohio App.3d 675 (2009) (constructive possession may be inferred from surrounding facts and defendant’s actions)
State v. Cherry, 171 Ohio App.3d 375 (2007) (constructive-possession principles applicable to weapons-under-disability charges)