State v. Sprinkle, 2022 Ohio 3182

Warren County Drug Task Force investigated Bowdie Reek; an undercover detective arranged a cocaine buy from Reek in a Meijer parking lot.
Reek used Corey Jewell’s silver Mercury; Jewell drove to the store, left, and Reek and Sprinkle (appellant) remained in the car.
After Jewell exited, Sprinkle moved to the driver’s seat and drove the car a short distance to a parking spot where Reek met the undercover detective and sold cocaine.
After the sale, officers arrested Reek and Sprinkle and recovered additional drugs and paraphernalia from the vehicle.
At trial Sprinkle was convicted of complicity to trafficking in cocaine; he appealed arguing insufficient evidence that he knowingly aided and abetted the sale.
The trial court admitted Sprinkle’s post-arrest statement in which he acknowledged prior assistance to Reek, saw drugs before the sale, and knew the trip involved dropping off drugs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Sprinkle knowingly aided and abetted trafficking in cocaine	The State: circumstantial evidence and Sprinkle's post-arrest statements show he knew the trip was for drugs, had previously assisted Reek, saw the drugs, stayed as driver, and thus aided the sale	Sprinkle: he was merely present; driving a short distance did not assist the sale and he lacked specific knowledge of the transaction	Court affirmed: evidence, including Sprinkle's admissions and conduct, was sufficient for a jury to find he knowingly aided and abetted the trafficking

State v. Diar, 120 Ohio St.3d 460 (2008) (sets the sufficiency-of-evidence standard: whether any rational trier of fact could find elements proven beyond a reasonable doubt)
State v. Johnson, 93 Ohio St.3d 240 (2001) (mere presence at a crime is insufficient to prove aiding-and-abetting; active participation is required)