State v. Wells, 2017 Ohio 420

On Jan. 20, 2015, Ryan Patrick went to Austin Wells’s home and exchanged prescription Klonopin for what Wells described as “dope.” Patrick injected the substance and immediately overdosed; he was later pronounced dead. Toxicology showed benzodiazepine, cocaine metabolites, and fentanyl.
Wells was arrested after also overdosing the next day; while hospitalized he gave a recorded statement admitting Patrick traded Klonopin for drugs and that Patrick “fell out” quickly; Wells said the drug "probably had fentanyl in it."
Indicted for involuntary manslaughter (R.C. 2903.04(A), felony 1) predicated on corrupting another with drugs (R.C. 2925.02(A)(3), felony 2), Wells was convicted by a jury and sentenced to 10 years after the state elected involuntary manslaughter.
Wells moved for acquittal under Crim.R. 29; the trial court denied the motion. He raised sufficiency and manifest-weight challenges on appeal and argued the state failed to prove he furnished the fentanyl/cocaine mixture that caused death.
Wells also argued ineffective assistance of counsel because trial counsel did not move to suppress his hospital statement; he claimed his post-overdose condition rendered any waiver involuntary.
The trial court relied on witness testimony (fiancé, coroner, paramedic, detective, toxicologist) and the recorded statement; the appellate court affirmed convictions and rejected the ineffective-assistance claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency / manifest weight / denial of Crim.R. 29 (causation and furnishing drugs)	State: circumstantial and direct evidence (Wells’s admission, scene evidence, toxicology, coroner) established Wells furnished a controlled substance and that fentanyl caused death.	Wells: no proof he provided fentanyl/cocaine (no drugs recovered); toxicologist said similar fentanyl level could be nonfatal; thus evidence insufficient/against weight.	Affirmed: evidence (including admissions, scene, and coroner’s opinion) was sufficient; jury did not lose its way on causation or furnishing.
Ineffective assistance for not moving to suppress hospital statement	State: recorded waiver and interview were voluntary; officer observed Wells coherent; motion to suppress would likely fail.	Wells: post-overdose condition undermined voluntariness and knowing waiver; suppression motion should have been filed.	Affirmed: counsel not ineffective—record shows Miranda warnings, coherent responses, short recorded interview; no reasonable probability suppression would have succeeded.

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for manifest-weight review)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (legal sufficiency standard for criminal convictions)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial-interrogation warnings and waiver standard)
State v. Lovelace, 137 Ohio App.3d 206 (Ohio Ct. App. 1999) (proximate cause analysis where defendant sets in motion events leading to death)
State v. Dennis, 79 Ohio St.3d 421 (Ohio 1997) (voluntariness and waiver evaluated under totality of circumstances)