State v. Williams, 2020 Ohio 4430

Rubin Williams was indicted for first-degree felony involuntary manslaughter (death "as a proximate result" of drug trafficking) and for selling fentanyl after a Salem woman died following injection of a pink substance. A jury convicted Williams and he was sentenced to 11 years.
Evidence: the decedent was found seated with an uncapped syringe, a spoon with pink residue, and a folded packet containing a pink substance; BCI identified the packet as fentanyl; toxicology showed fentanyl plus benzodiazepines, dextromethorphan, and gabapentin.
Key witness Nicole testified she acted as Williams’s drug runner, delivered the packet to the decedent after receiving it from Williams, returned the $40 to Williams, and had nearly overdosed on the same pink substance a day earlier while Williams was present.
The coroner (internal medicine background, former pharmacist) testified the death was asphyxia from mixed drug overdose, that the fentanyl level was lethal, and that the decedent would not have died but for the fentanyl.
Williams argued the state failed to prove causation (actual and proximate) because other drugs were present and relied on Burrage; he also challenged the verdict as against the manifest weight of the evidence.

Issue	State's Argument (Plaintiff)	Williams' Argument (Defendant)	Held
Sufficiency — causation (actual/but‑for)	Evidence (Facebook messages, runner testimony, packet on table, toxicology, coroner) shows Williams supplied fentanyl that was the but‑for cause of death.	Burrage requires proof that the victim would not have died but for the defendant’s drug; mixed‑drug overdose means the state failed to show but‑for causation.	Court upheld sufficiency: coroner’s opinion and circumstantial facts support that fentanyl provided by Williams was the but‑for (and here independently lethal) cause.
Sufficiency — proximate (legal) cause / foreseeability	Sale of heroin (and fentanyl) makes overdose a foreseeable result; supplying fentanyl makes death especially foreseeable.	State did not prove the death was a foreseeable result of Williams’s conduct.	Court held proximate cause proven: overdose from sold drugs (especially fentanyl) was a foreseeable consequence.
Manifest weight of the evidence	Witness credibility and physical/circumstantial evidence support the verdict; jury entitled to credit runner and coroner.	Jury lost its way on causation; alternate explanations and contested testimony undermine verdict.	Court declined to substitute its judgment for the jury; verdict was not against the manifest weight of the evidence.

Burrage v. United States, 571 U.S. 204 (2014) (federal Court clarifying that the "death results" enhancement requires but‑for causation where the distributed drug is not independently sufficient to cause death)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
Thompkins v. Ohio, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency and manifest‑weight review)
State v. Franklin, 62 Ohio St.3d 118 (1991) (circumstantial evidence can sustain conviction)
Ackison v. Anchor Packing Co., 120 Ohio St.3d 228 (2008) (but‑for test is standard for cause in fact)
Pang v. Minch, 53 Ohio St.3d 186 (1990) (substantial‑factor analysis in civil multiple‑cause cases)
State v. Lang, 129 Ohio St.3d 512 (2011) (treatment of expert certainty and weight issues in criminal trials)
State v. D'Ambrosio, 67 Ohio St.3d 185 (1993) (experts may testify in terms of possibility; certainty affects weight not admissibility)