State v. Simpson, 109 N.E.3d 595

Michael Simpson was indicted for possession and trafficking: cocaine (~190.424 g) and heroin (~1.965 g); pled not guilty and was tried by jury.
Trooper recovered drugs hidden in a Chex Mix bag in the rear floor area; recording captured Simpson telling a passenger not to speak; passenger testified Simpson tried to hand her something and urged concealment.
Jury convicted Simpson of possession and trafficking for both drugs; the trial court merged possession into trafficking for each drug and sentenced on trafficking counts.
The court found Simpson a "major drug offender" under R.C. 2925.03(C)(4)(g) and imposed the mandatory maximum of 11 years for first-degree trafficking (cocaine) plus consecutive 18 months for heroin.
Simpson appealed solely arguing the court erred by classifying him a major drug offender because R.C. 2929.01(W) defines that status by convictions for "possession, sale, or offer to sell," and he was convicted under the trafficking subsection covering transport/distribute (A)(2), not sale/offering (A)(1).
The State relied on R.C. 2925.03(C)(4)(g) (specific trafficking provision) and the drug-weight evidence, arguing the trafficking statute itself designates an offender a major drug offender when the cocaine amount equals or exceeds 100 grams.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court properly classified Simpson a "major drug offender"	State: R.C. 2925.03(C)(4)(g) specifically makes trafficking ≥100 g of cocaine a major drug offender, so classification is authorized	Simpson: R.C. 2929.01(W) defines major drug offender as convicted of "possession, sale, or offer to sell" ≥100 g; he was convicted under trafficking (A)(2) not sale/offer/possession after merger, so statute doesn’t apply	Court: R.C. 2925.03(C)(4)(g) is the more specific, later-enacted provision that controls; classification upheld
Whether weight evidence was sufficient to support the major drug offender finding	State: Laboratory report showed 190.424 g of cocaine; Gonzales holding on including fillers applies to trafficking too	Simpson: Implicit challenge to sufficiency of proof of cocaine weight	Court: Evidence supported finding cocaine amount ≥100 g; a rational trier of fact could so find

State v. Straley, 139 Ohio St.3d 339 (statutory interpretation reviewed de novo)
State v. Whitfield, 124 Ohio St.3d 319 (guilt for merged allied offenses remains intact after merger for sentencing)
State v. Gonzales, 150 Ohio St.3d 276 (entire compound including fillers counts toward cocaine weight)
State v. Moaning, 76 Ohio St.3d 126 (Revised Code construed as an interrelated body of law)
Davis v. State Personnel Bd. of Rev., 64 Ohio St.2d 102 (specific, later statute controls over a general statute)
SER Clay v. Cuyahoga Cty. Med. Examiner's Office, 152 Ohio St.3d 163 (statutory-construction principles on specific versus general provisions)