State v. Seldon, 2013 Ohio 819

Traffic stop in Solon, Ohio (Mar. 12, 2011) of Seldon driving a friend's pickup with Tarin Trippett; nighttime stop following non-illuminated license plate; dog sniff around vehicle after initial contact.
K-9 dog Striker alerted to the passenger-side door area after a walk-around of the vehicle.
Recovered items include pseudoephedrine, iodine, matches, starter fluid, brake cleaner, Heet, Sudafed pills, and a homemade sword.
Seldon admitted some items were his and for legitimate purposes; denied intent to manufacture methamphetamine.
Jury convicted Seldon of assembly or possession of chemicals used to manufacture a controlled substance; sentenced to 18 months of community control.
Court reversed and remanded, finding the evidence insufficient to prove intent to manufacture methamphetamine and declining to address other assignments of error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the dog sniff during the stop violated the Fourth Amendment/Ohio Const.	Seldon argues lack of reasonable suspicion.	Seldon contends stop escalated without basis.	Not reached (dispositional issues take precedence).
Whether the trial court erred by admitting expert opinion on intent.	State relied on expert; intrusion of opinion on intent.	Seldon challenges credibility of expert testimony.	Not reached (dispositional issues take precedence).
Whether there was sufficient evidence of intent to manufacture methamphetamine.	State asserts sufficient inferential chain from possession to intent.	Seldon contends mere possession cannot prove intent.	Insufficient evidence of intent; conviction vacated.
Whether the conviction was against the manifest weight of the evidence.	State argues evidence supports guilt beyond weight.	Seldon asserts weight favors acquittal.	Weight of the evidence not sustained; remanded.
Whether defense counsel provided ineffective assistance.	Ineffective assistance for suppression and challenge to expert.	Counsel failed to suppress and object appropriately.	Not reached (dispositional issues take precedence).

State v. Bridgeman, 55 Ohio St.2d 261 (Ohio Supreme Court 1978) (sufficiency standard for criminal convictions; Bridgeman interpreted with Jenks)
State v. Jenks, 61 Ohio St.3d 259 (Ohio Supreme Court 1991) (the 'reasonable doubt' sufficiency standard; review of evidence in light most favorable to State)