State v. Stewart, 2023 Ohio 253

On Sept. 5, 2020, corrections officers at NCCI searched Keisonn Stewart and found multiple one-inch squares of paper suspected to be synthetic cannabinoid in his left sock; buprenorphine was found on his TV stand.
The paper was submitted to the Ohio State Highway Patrol Crime Lab and tested positive for MDMB-4en-PINACA (a synthetic cannabinoid).
A superseding indictment charged Stewart with Count One: aggravated possession of drugs (fifth-degree felony) based on the sock contraband, and Count Two: possession (related to buprenorphine).
Jury trial in October 2021 resulted in a guilty verdict on Count One and not guilty on Count Two; Stewart was sentenced to 11 months’ imprisonment.
On appeal Stewart challenged both the sufficiency and the manifest weight of the evidence, chiefly arguing there was scant proof linking him to the contraband and that the corrections officer could not identify the trial photographs.
The Third District affirmed: lab testing and the officer’s discovery of the paper in Stewart’s sock supplied sufficient evidence; credibility and weight determinations were for the jury, and no manifest miscarriage of justice occurred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support aggravated-possession conviction (R.C. 2925.11(A))	Contraband was found on Stewart (in his sock), chain of custody preserved, and lab confirmed a synthetic cannabinoid	Evidence was "scant" to connect Stewart to the items; officer couldn’t positively ID the photos	Affirmed — viewing evidence for the State, a rational trier of fact could find guilt beyond a reasonable doubt
Whether the conviction is against the manifest weight of the evidence	Jury was entitled to credit State witnesses; chain of custody and lab results support conviction	Officer’s inability to identify Defendant’s Exhibit 1 undermines credibility and the verdict’s weight	Affirmed — credibility and weight are for the trier of fact; no extraordinary circumstances to reverse

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency and manifest-weight standards)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review: evidence must permit a rational trier of fact to find guilt beyond a reasonable doubt)
State v. Teamer, 82 Ohio St.3d 490 (1998) (possession and knowledge determined from attendant facts and circumstances)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight of evidence are for the trier of fact)
State v. Martin, 20 Ohio App.3d 172 (1983) (formulation of the manifest-weight test and when reversal is warranted)
State v. Hunter, 131 Ohio St.3d 67 (2011) (appellate reversal for manifest weight is appropriate only in exceptional cases)