State v. Taylor, 2020 Ohio 5097

In April 2019 Herbert Taylor was indicted for first-degree felony possession of cocaine (with forfeiture) after a controlled postal delivery to 222 Penn Ave., Mansfield, Ohio.
Postal inspectors and a K-9 detected cocaine in a package; investigators repackaged the narcotics with a GPS/box-beacon and performed a controlled delivery.
During delivery on February 8, 2019, Taylor retrieved the package from a vehicle, reentered a waiting car driven by Akili Roberts, and opened the package en route; the box beacon alarm later activated.
Officers stopped the vehicle and found the package (containing a total of 489.1 g of cocaine, 119.7 g on Taylor), cash on both men, photos of drugs on Taylor’s phone, and a screenshot of the package tracking number on Roberts’ phone.
Taylor testified he lived off-site, had rented the house, picked up the package for the renter (who was jailed), opened it out of curiosity, and lacked proof of funds; he denied prior knowledge of narcotics.
A jury convicted Taylor; the trial court sentenced him to the mandatory 11-year term. Taylor appealed, arguing (1) conviction against the manifest weight of the evidence and (2) plain error for not dismissing a juror who made a comment in the restroom.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the conviction against the manifest weight of the evidence?	State: circumstantial + direct evidence (Taylor grabbed and opened package, package on his lap at arrest, photos of drugs on his phone, tracking info on co-defendant’s phone) show knowing possession.	Taylor: he merely retrieved the package for the renter and opened it out of curiosity; no proof he knowingly possessed the cocaine.	Affirmed. Court found sufficient circumstantial evidence of constructive possession; jury credibility determinations stand.
Did the trial court commit plain error by not dismissing Juror No. 5 after restroom comment?	State: trial court investigated, juror denied forming opinion, juror was made alternate; no prejudice shown.	Taylor: juror misconduct warranted dismissal.	Affirmed. No plain error—alternate juror substituted, no prejudice or manifest miscarriage of justice shown.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (establishes manifest-weight standard)
State v. Martin, 20 Ohio App.3d 172 (1983) (discusses reversal when jury clearly loses its way)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight are for the trier of fact)
State v. Butler, 42 Ohio St.3d 174 (1989) (constructive possession principles)
State v. Wolery, 46 Ohio St.2d 316 (1976) (dominion and control as elements of constructive possession)
State v. Trembly, 137 Ohio App.3d 134 (2000) (circumstantial evidence can establish constructive possession)
State v. Teamer, 82 Ohio St.3d 490 (1998) (knowledge to possess is determined from all attendant facts and circumstances)
State v. Long, 53 Ohio St.2d 91 (1978) (plain-error review standards)
State v. McKnight, 107 Ohio St.3d 101 (2005) (plain-error and juror-misconduct guidance)