State v. Samples
2013 Ohio 986
Ohio Ct. App.2013Background
- One-car accident on Eastern Road in Medina, Ohio; Samples charged with driving under the influence of a drug of abuse, failure to control, and refusing a chemical test.
- Bench trial conviction on all charges; sentencing included 60 days jail (suspended), 1-year license suspension, $475 DUI drug fine; 20 days for refusing a test; failure-to-control dismissed; jail terms run concurrently.
- Samples timely appealed challenging the weight and sufficiency of the evidence linking impairment to a drug of abuse.
- State witnesses testified Samples appeared impaired, but did not specify a particular drug or link impairment to a controlled substance, harmful intoxicant, or dangerous drug.
- Appellate court applied sufficiency review, determining the State must show impairment caused by a drug of abuse under R.C. 3719.011(A) with nexus to the specified categories.
- The court reversed Samples’ DWI-drug conviction and remanded for proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence proves impairment from a drug of abuse beyond a reasonable doubt | Samples argues the evidence was insufficient and the weight favors acquittal. | State argues witnesses showed impairment due to drugs, supporting the DWI-drug conviction. | Sustained; conviction reversed and remanded. |
Key Cases Cited
- State v. Collins, 2012-Ohio-2236 (9th Dist. No. 11CA0027 (2012)) (reversed where impairment lacking nexus to drug of abuse)
- State v. Jenks, 61 Ohio St.3d 259 (Ohio Supreme Court 1991) (standard for sufficiency review)
- Thompkins, 78 Ohio St.3d 380 (Ohio Supreme Court 1997) (concurrence on sufficiency framework)