State v. Reese, 2016 Ohio 1591

In April–May 2015 the Zanesville–Muskingum County Drug Task Force conducted controlled buys of cocaine from Darren M. Reese and executed a search warrant on June 1, 2015.
Transactions involved multiple quantities: ~51.4g, 27.4g, ~105g (dry)/149.65g (wet), and ~14.62g (dry)/26.69g (wet); the search produced 83.13g of cocaine.
Reese was indicted on four counts of trafficking (R.C. 2925.03(A)(1)), one count of illegal manufacture (R.C. 2925.01(A)), and one count of possession (R.C. 2925.11(A)).
Reese moved to obtain a purity analysis of the cocaine; the State opposed.
Reese pleaded no contest and stipulated to the lab results (which did not state purity). He was sentenced to 16 years total and appealed, arguing the convictions/sentences were based on total compound weight rather than the weight of pure cocaine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State must prove the weight of the pure cocaine (excluding fillers) to meet statutory thresholds for trafficking/major-offender specifications	State relied on lab identity and total compound weight to satisfy statutory weight thresholds	Reese argued convictions/sentences improperly used total compound weight instead of weight of pure cocaine	Court affirmed: under controlling Fifth District precedent (Chandler), State need only prove identity and a detectable amount; assignment of error overruled

State v. Chandler, 157 Ohio App.3d 672 (5th Dist. 2004) (establishes that prosecution must prove identity and a detectable amount of the controlled substance)
State v. Chandler, 109 Ohio St.3d 223 (Ohio 2006) (Ohio Supreme Court affirmed the Fifth District’s ruling)