State v. Allen

Summary

The Ohio Third District Court of Appeals reviewed Jalen Arthur-Darnell Allen’s convictions for engaging in a pattern of corrupt activity and trafficking in fentanyl-related compounds. The court affirmed the convictions but reversed aspects of sentencing, holding that the trial court improperly ordered a de facto forfeiture of seized funds, failed to properly determine indigency before imposing a mandatory fine, and failed to make the required proportionality finding for consecutive sentences. The case was remanded for further sentencing proceedings.

Holdings

1. The evidence was sufficient to establish an enterprise and a pattern of corrupt activity because Allen and Jajuan worked together for the common purpose of selling drugs and the evidence showed three separate drug transactions.
2. The evidence was sufficient to support Allen's trafficking convictions, including the first sale under a complicity theory.
3. Allen's convictions were not against the manifest weight of the evidence.
4. The trial court erred by ordering a de facto forfeiture of seized funds after the State dismissed the forfeiture specifications and the jury did not determine that the funds were subject to forfeiture.
5. The trial court erred by imposing the mandatory fine without clearly determining whether Allen was indigent and unable to pay it.
6. The trial court erred by imposing consecutive sentences without making the required proportionality finding at the sentencing hearing.

Questions Presented

1. Whether sufficient evidence supported Allen's convictions for engaging in a pattern of corrupt activity and trafficking in a fentanyl-related compound.
2. Whether the convictions were against the manifest weight of the evidence because they depended substantially on the confidential informant's credibility.
3. Whether the trial court unlawfully ordered seized funds to be forfeited or applied toward Allen's fine after the State dismissed the forfeiture specifications and the jury made no forfeiture determination.
4. Whether the trial court properly imposed a mandatory fine after Allen filed an affidavit of indigency.
5. Whether the trial court made all findings required by R.C. 2929.14(C)(4) before imposing consecutive sentences.

Disposition

reversed_and_remanded