State v. Young, 2020 Ohio 1044

Young used Snapchat to arrange a marijuana sale with Price and directed Price to meet at an apartment in Fairborn.
When Price entered the apartment with Young, DeAndre DaCosta produced a gun, assaulted Price, and took $1,650; Price suffered a concussion and other injuries.
Young sat on the couch during the attack, did not intervene, and left through the back door while the assault continued; a co-defendant testified Young said a pistol “would be good to use” and had marijuana in his backpack.
Young was indicted for aggravated robbery and conspiracy; the conspiracy count was dismissed on a Crim.R. 29 motion, and the jury convicted Young of complicity to commit aggravated robbery.
Young was sentenced to a definite 10-year prison term (a mandatory term triggered by a prior first-degree felony conviction).
On appeal Young raised three arguments: (1) the indictment failed to put him on notice of a complicity theory, (2) insufficient evidence supported complicity, and (3) his sentence was excessive and the indictment should have disclosed the mandatory nature of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether indictment gave notice that jury could convict on complicity theory	State: charging in terms of principal offense is sufficient; complicity may be charged under R.C. 2923.03(F)	Young: indictment did not explicitly charge complicity, so he lacked notice of that theory	Court: indictment adequate; R.C. 2923.03(F) and Ohio precedent permit complicity conviction though indictment tracks principal offense
Sufficiency of evidence for complicity (aiding and abetting)	State: evidence showed Young arranged the buy, escorted Price in, restricted accompaniments, referenced use of a gun, and had marijuana—supporting aiding/abetting and shared intent	Young: he was only present and did not participate in the assault; mere presence insufficient	Court: evidence, viewed in the light most favorable to the prosecution, was sufficient for a rational juror to find Young aided and abetted the aggravated robbery
Sentence legality and excessiveness; indictment notice of mandatory term	State: sentence within statutory range; trial court considered R.C. 2929.11/2929.12; indictment need not state sentencing consequences	Young: 10-year mandatory term excessive and indictment should have given notice that sentence would be mandatory	Court: sentence (3–11 yrs statutory range) was lawful and not contrary to law; trial court considered required factors; indictment need not notify defendant of mandatory sentencing consequences

State v. Hand, 107 Ohio St.3d 378 (Ohio 2006) (R.C. 2923.03(F) permits charging in terms of the principal offense and gives notice that a complicity instruction may be given)
State v. Herring, 94 Ohio St.3d 246 (Ohio 2002) (defendant may be convicted as complicit even if indictment is phrased in terms of the principal offense)
State v. Keenan, 81 Ohio St.3d 133 (Ohio 1998) (complicity notice principles apply under the complicity statute)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for appellate sufficiency-of-the-evidence review)
State v. Johnson, 93 Ohio St.3d 240 (Ohio 2001) (complicity by aiding and abetting requires support/assistance and shared criminal intent; intent may be inferred)
State v. Arrington, 64 Ohio App.3d 654 (Ohio Ct. App. 1990) (mere presence at the scene is insufficient to establish complicity)