State v. Wright
2011 Ohio 5641
Ohio Ct. App.2011Background
- Wright was arrested after a shopper reported a suspicious Adderall sale to a buyer with children present.
- Wright confessed to selling six Adderall pills to Margaret Leasure for $25.
- Wright provided a written statement denying coercion and indicating she understood her rights, without an attorney present.
- Leasure independently confirmed receiving Adderall, but later claimed the pills were Aleve.
- Wright was charged with Aggravated Trafficking in Drugs under R.C. 2925.03(A)(1), a third-degree felony, and the trial court sentenced her to two years of community control.
- Appeals court affirmed the conviction and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly admitted the confession under corpus delicti. | Wright contends admission violated corpus delicti. | State argues proof of act and criminal agency existed. | No reversible error; corpus delicti evidence deemed sufficient. |
| Whether there was plain or sufficient evidence to sustain conviction. | Wright asserts insufficient evidence. | State asserts evidence supported sale of Adderall in presence of juveniles. | Evidence sufficient to support conviction beyond reasonable doubt. |
| Whether Wright preserved error regarding suppression motion. | Wright argues trial court erred in not ruling on suppression/holding an evidentiary hearing. | State contends the record shows forfeiture of the issue due to lack of preservation. | Forfeited; not addressed on appeal. |
Key Cases Cited
- State v. Childs, 14 Ohio St.2d 56 (Ohio 1968) (plain-error and preservation considerations in appellate review)
- State v. Glaros, 170 Ohio St. 471 (Ohio 1960) (preservation and plain-error principles; corpus delicti considerations)
- State v. Chandler, 109 Ohio St.3d 223 (Ohio 2006) (evidence can prove an element via circumstantial proof; direct evidence not required for A(1) trafficking")
- State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard of proof and circumstantial evidence admissibility)
- Garr v. Warden, Madison Corr. Inst., 126 Ohio St.3d 334 (Ohio 2010) (recognizes Jenks standard; clarifies Chandler limitations on proof of substance content)
- State v. Maranda, 94 Ohio St. 364 (Ohio 1916) (corpus delicti origins and evidentiary requirements)
- State v. Van Hook, 39 Ohio St.3d 256 (Ohio 1988) (corpus delicti evidence sufficiency requires some proof of act and criminal agency)