State v. Reeves, 2014 Ohio 282

Detective Harvey received information of drug sales from 771 East Exchange St.; informant described seller as black male, nicknamed “O” or “OC.”
A Mazda with Illinois plates was identified as a vehicle of interest linked to the apartment and narcotics activity.
Police obtained a search warrant; Reeves was stopped/driven back to the apartment when found with a key to the apartment, a cell phone, and $1,560 in cash.
Inside the apartment, officers found a bindle of heroin, three handguns under the mattress, and other drug paraphernalia; Reeves had residency indicators there.
Brazile, a resident, cooperated with officers; Reeves admitted staying at the apartment from time to time; evidence suggested Reeves’ involvement in drug activity.
A jury convicted Reeves of heroin possession and having weapons while under disability, and forfeiture of the $1,560 cash was ordered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Reeves argues no proof of possession or firearms.	Prosecution failed to show knowledge or control.	Convictions upheld; evidence sufficient.
Manifest weight of the evidence	Weight favors Brazile; Reeves did not possess jointly.	Weight favors defendant due to shared occupancy.	Convictions not against the weight of the evidence.
Forfeiture propriety of cash proceeds	Cash derived from offense subject to forfeiture; proportionality review required.	Proportionality review should apply to forfeiture.	No proportionality review required when proceeds; forfeiture affirmed.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (established sufficiency review de novo)
State v. Jenks, 61 Ohio St.3d 259 (1991) (directed evidence review for sufficiency)
State v. Robinson, 162 Ohio St.486 (1955) (juror standard for sufficiency)
State v. Salupo, 177 Ohio App.3d 354 (2008) (sufficiency de novo review applicable in appellate court)
State v. Otten, 33 Ohio App.3d 339 (1986) (thirteenth juror weight review)