State v. Samuels, 2012 Ohio 5401

Samuels was convicted in three consolidated Summit County cases arising from methamphetamine-related conduct in Aug. 2010, Oct. 2010, and Feb. 2011.
August incident: police found an active meth lab in his brother’s apartment, Samuels asleep on a bed amid cooking meth, and meth-positive coffee filters and pseudoephedrine in his car.
October incident: at Kmart he fled with Coleman fluid, and a car stop revealed Coleman fluid, grinder with trace pseudoephedrine, used filters, bags with meth traces, and other meth-production items.
February incident: police discovered meth paraphernalia in a Springfield Township home and a vial on Samuels’ person testing positive for trace meth.
Trial court sentenced six years for illegal manufacturing, with concurrent terms on the other counts; three cases were appealed and consolidated on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was joinder of the three cases plain error?	Samuels argues joinder prejudiced his defense.	Samuels contends consolidation created prejudice by muddling separate defenses.	No plain error; joinder permissible because evidence was simple and distinct.
Did trial counsel’s failure to move to sever constitute ineffective assistance?	Samuels claims relief due to failure to sever prejudicial joinder.	No ineffective assistance because joinder not prejudicial.	No ineffective assistance; joinder held non-prejudicial.

State v. Schaim, 65 Ohio St.3d 51 (1992) (Crim.R.14 prejudice analysis for joined charges)
State v. Hamblin, 37 Ohio St.3d 153 (1988) (evidence simplicity allows reasonable juror segregation)
State v. Lott, 51 Ohio St.3d 160 (1990) (joinder vs. severance prejudice framework)