State v. Secriskey
2017 Ohio 4169
| Ohio Ct. App. | 2017Background
- April 12, 2015: Secriskey sought hospital treatment for chemical burns to his face; hospital reported the injuries to police. Officers went to his apartment and observed a chemical odor, open windows, and three discarded bottles outside they believed were consistent with one‑pot methamphetamine production; they later found meth lab materials and an exploded bottle inside.
- October 4, 2015: Officer found Secriskey slumped in his car; he was disoriented and lacked a valid license. Officers found a baggie with white powder and paraphernalia including methamphetamine and syringes in the vehicle.
- Charges: Criminal case for illegal manufacture of methamphetamine (within 1,000 feet of a school) from April incident; aggravated possession, possession of drug abuse instruments, and driving under suspension from October incident.
- Pretrial: Secriskey moved to suppress evidence from the warrantless apartment entry; the trial court denied the motion. The court consolidated the two cases over defense objection.
- Trial and sentence: Jury convicted on all counts. Sentences totaled eight years consecutive.
- Appeal: Secriskey appealed, arguing (1) the warrantless apartment entry violated the Fourth Amendment (motion to suppress should have been granted) and (2) insufficient evidence/manifest weight challenge to the illegal manufacture conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether warrantless entry/search of apartment was lawful under emergency-aid/exigent-circumstances (meth lab risk) | State: Officers reasonably believed, from bottles outside, chemical odor, open windows, victim with chemical burns, and possible child in apartment, that an active meth lab posed imminent danger justifying immediate entry. | Secriskey: No exigency — officers waited ~1 hour, knocked on neighboring units, smelled chemicals (not burning), and could have obtained a warrant. | Court affirmed denial of suppression: officers had an objectively reasonable belief of an active meth lab and peril (R.C. 2933.33(A)/emergency-aid exception); entry was reasonable. |
| Whether evidence was sufficient to support illegal manufacture conviction | State: Testimony and physical evidence (pseudoephedrine purchase traced to Secriskey, spent one‑pot bottles outside, exploded bottle and lab materials inside, co-defendant eyewitness account) establish knowing manufacture. | Secriskey: Only direct link is pseudoephedrine purchase; circumstantial items do not tie him to manufacture. | Court held evidence was sufficient: circumstantial and direct evidence together could convince a rational juror beyond a reasonable doubt. |
| Whether conviction was against manifest weight of the evidence | N/A | Secriskey argued manifest weight mirrors sufficiency claim. | Court rejected the claim — defendant did not challenge witness credibility or otherwise show the jury lost its way; conviction not against manifest weight. |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of review for motions to suppress; appellate deference to trial court factual findings)
- Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (warrantless searches presumptively unreasonable except for established exceptions)
- Katz v. United States, 389 U.S. 347 (1967) (Fourth Amendment protection for reasonable expectations of privacy)
- State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency review: evidence viewed in light most favorable to prosecution)
- Thompkins v. Ohio, 78 Ohio St.3d 380 (1997) (manifest-weight review and standard for reversal)
- Tibbs v. Florida, 457 U.S. 31 (1982) (appellate court as thirteenth juror when reviewing weight of the evidence)