State v. Andrews

Citations

• 2025 Ohio 2147

Syllabus

Sufficiency of the evidence, manifest weight of the evidence, having weapons while under disability, tampering with evidence, controlled buy, confidential reliable informant, Evid.R. 702, expert-opinion testimony. Andrews appealed convictions for aggravated trafficking in drugs, aggravated possession of drugs, possessing criminal tools, having weapons while under disability (\HWWUD\), and tampering with evidence. Insufficient evidence supported HWWUD conviction because officer testimony established only that Andrews walked near an area in an open field where a gun was later found. Insufficient evidence supported tampering with evidence conviction because nothing in the record indicated Andrews knew of investigation when he discarded drugs in open field. Testimony that Andrews had cash on his person that police had previously used in a \controlled buy\ did not require disclosure of informant identity because Andrews was not charged with selling drugs to the informant. Testimony that drug dog alerted to presence of illegal drugs in Andrews's car was not expert-opinion testimony because officer was interpreting dog's behavior based on his own firsthand observations.