State v. Stull, 2012 Ohio 3444

Stull was convicted in Summit County for possession of heroin, cocaine, marijuana, drug paraphernalia, and child endangering after a SWAT raid on the Victoria Avenue home she shared with Stallings.
Stull resided there with her ten-year-old daughter and Stallings in October 2010 when officers executed a search warrant.
Stallings discarded a bag containing heroin, cocaine, and marijuana from the master bedroom window; officers later found drugs and paraphernalia in the home.
Stull and Stallings were charged separately; the cases were severed on motion.
Stull appeals asserting ineffective assistance of counsel and evidentiary errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for trial counsel	Stull's attorneys failed to object to Stallings’ drug-history evidence	Counsel’s performance fell within reasonable professional assistance	First assignment of error overruled
Admission of Stallings’ prior drug history	Evidence was relevant to show knowledge; not unfairly prejudicial	Probative value outweighed by prejudice	Evidence admissible; not reversible error; not prejudicial

State v. Robb, 88 Ohio St.3d 59 (2000) (admissibility and relevance standards for evidentiary rulings)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
State v. Srock, 2006-Ohio-251 (9th Dist.) (prejudice prong in ineffective assistance claims)
State v. Bradley, 42 Ohio St.3d 136 (1989) (prejudice standard for ineffective assistance)
Clayton, 62 Ohio St.2d 45 (1980) (trial tactics are not ineffective assistance)
State v. Wade, 2003-Ohio-2351 (9th Dist.) (abuse of discretion standard in evidentiary rulings)
Long, 53 Ohio St.2d 91 (1978) (evidentiary relevance and prejudice framework)
Allen, 73 Ohio St.3d 626 (1995) (evidentiary rule application guidance)