State v. Reis, 2012 Ohio 2482

Reis was involved in a single-vehicle accident on Route 8 South and had a suspended license.
Police inventory search of Reis’s car yielded a small blue pill and baggies; Reis denied knowledge of the pill.
Pill tested positive for MDMA; Reis was indicted for aggravated possession of drugs, driving under suspension, and failure to control.
Reis pled guilty to driving under suspension and failure to control; a bench trial determined she possessed the alleged drug.
The trial court convicted Reis of aggravated possession and sentenced her to two years of community control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for possession	Reis argues the State lacked proof she knowingly possessed the pill.	Reis contends there is no evidence of knowledge or possession by her.	Sufficiency established; circumstantial evidence supports constructive possession.
Weight of the evidence	Reis claims the evidence proves she did not knowingly possess the pill.	Reis asserts the verdict rests on insufficient credibility and weight.	Conviction not against the manifest weight; record supports the trial court’s credibility determinations.

State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency review standard)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (sufficiency and reasonable doubt guidance)
State v. Kendall, 2012-Ohio-1172 (9th Dist.) (constructive possession framework)
State v. Hankerson, 70 Ohio St.2d 87 (1982) (definition of possession and knowledge)
State v. Graves, 2011-Ohio-5997 (9th Dist.) (constructive possession and proximity)
State v. Lamb, 2007-Ohio-5107 (9th Dist.) (circumstantial evidence supports possession)
State v. Williams, 2011-Ohio-4488 (9th Dist.) (circuits on possession and availability)