[T]he jury afforded more weight to the State’s evidence than Mr. Stackhouse’s version of events.

 

State v. Stackhouse

2025 – Ohio – 5464

Third District Appellate Court

Seneca County, Ohio

December 8, 2025

Why is this case important?

State v. Stackhouse is important because it reinforces how Ohio courts analyze “knowing possession” under O.R.C. §2925.11 when drugs are found in a vehicle after a crash and the defendant later attempts to recant an on-scene admission. The Third District makes clear that a defendant’s own statements, combined with plain-view evidence and proximity to contraband, can independently support a finding of actual or constructive possession.

Background

Defendant-appellant, Tyrice Stackhouse, appeals the January 14, 2025 judgment entry of sentence of the Seneca County Court of Common Pleas. For the reasons that follow, we affirm.

Single Vehicle Accident in Fostoria

This case stems from a single-vehicle accident in Fostoria, Ohio, where Mr. Stackhouse was found therein unresponsive. The vehicle, which was registered to his then girlfriend, April Iannantuono, contained large quantities of drugs that Mr. Stackhouse initially claimed were his, allegedly to protect Ms. Iannantuono.

Indicted

On June 20, 2024, the Seneca County Grand Jury indicted Mr. Stackhouse on Count One of aggravated possession of drugs in violation of O.R.C. §2925.11(A), (C)(1)(c), a second-degree felony; Count Two of possession of cocaine in violation of O.R.C. §2925.11(A), (C)(4)(e), a first-degree felony; and Count Three of possession of a fentanyl-related compound in violation of O.R.C. §2925.11(A), (C)(11)(b), a fourth-degree felony. On August 28, 2024, Mr. Stackhouse appeared for arraignment and pleaded not guilty.

Jury Trial and Conviction

The case proceeded to a jury trial on December 16-17, 2024. Before the presentation of evidence, the State moved to exclude evidence of Ms. Iannantuono’s prior criminal (drug) conduct that resulted in an intervention in lieu of conviction. On December 17, 2024, the jury found Mr. Stackhouse guilty of all three counts alleged in the indictment.

Prison Term of Fourteen to Eighteen Years in Prison

On January 14, 2025, the trial court sentenced Mr. Stackhouse to a minimum term of 6 years to a maximum term of 9 years in prison on Count One; to a minimum term of 8 years to a maximum term of 12 years in prison on Count Two; and to 16 months in prison on Count Three. The trial court ordered the sentences imposed as to Counts One and Two to be served consecutively, and the sentence for Count Three to be served concurrently to the others, for an aggregate indefinite prison term of 14 to 18 years. The trial court also ordered this aggregate sentence to be served consecutively to a sentence that Mr. Stackhouse was already serving in a Wood County case.

Three Appeals

Mr. Stackhouse filed his notice of appeal on January 14, 2025. He raises three assignments of error for our review. First Assignment of Error Because the jury lost its way and created a manifest miscarriage of justice in convicting Appellant, Appellant’s convictions, with respect to all counts, were against the manifest weight of the evidence.

Trial Court Erred – Ms. Iannantuono Possessed the Narcotics

In his first assignment of error, Mr. Stackhouse argues that his convictions are against the manifest weight of the evidence. In particular, Mr. Stackhouse contends that the weight of the evidence reflects that Ms. Iannantuono was the one who actually possessed the drugs. Standard of Review

Did Mr. Stackhouse ‘Knowingly Possess’ the Narcotics?

Mr. Stackhouse was convicted of aggravated possession of drugs, possession of cocaine, and possession of a fentanyl-related compound. Ohio’s drug possession statute provides, in its relevant part, that “[N]o person shall knowingly obtain, possess, or use a controlled substance or a controlled substance analog.” O.R.C. §2925.11(A). To secure a conviction for drug possession under O.R.C. §2925.11(A), the State must prove the defendant “knowingly” possessed a controlled substance. “A person acts knowingly, regardless of purpose, when the person is aware that the person’s conduct will probably cause a certain result or will probably be of a certain nature. A person has knowledge of circumstances when the person is aware that such circumstances probably exist.” O.R.C. §2901.22(B).

Established Case Law on Possession

On appeal, Mr. Stackhouse argues his convictions are against the manifest weight of the evidence, contending that the evidence suggesting Ms. Iannantuono possessed the drugs is more compelling than the evidence against him. “‘Possess’ or ‘possession’ means having control over a thing or substance, but may not be inferred solely from mere access to the thing or substance through ownership or occupation of the premises upon which the thing or substance is found.” O.R.C. 2925.01(K). “The issue of whether a person charged with drug possession knowingly possessed a controlled substance ‘is to be determined from all the attendant facts and circumstances available.’” State v. Brooks, 2012-Ohio-5235, ¶ 45 (3d Dist.), quoting State v. Teamer, 82 Ohio St.3d 490, 492 (1998). {¶11} “Possession of drugs can be either actual or constructive.” State v. Bustamante, 2013-Ohio-4975, ¶ 25 (3d Dist.). “‘A person has “actual possession” of an item if the item is within his immediate physical possession.’” Id., quoting State v. Williams, 2004-Ohio-1130, ¶ 23 (4th Dist.). “A person has ‘constructive possession’ if he is able to exercise dominion and control over an item, even if the individual does not have immediate physical possession of it.” Id. “For constructive possession to exist, ‘[i]t must also be shown that the person was conscious of the presence of the object.’” Id., quoting State v. Hankerson, 70 Ohio St.2d 87, 91 (1982).

“[T]he State may prove the existence of the various elements of constructive possession of contraband by circumstantial evidence alone.” Id. See also Jenks, 61 Ohio St.3d at 272-273. “Readily usable drugs in close proximity to an accused may constitute sufficient circumstantial evidence to support a finding of constructive possession.” State v. Ruby, 2002-Ohio-5381, ¶ 36 (2d Dist.). “Absent a defendant’s admission, the surrounding facts and circumstances, including the defendant’s actions, are evidence that the trier of fact can consider in determining whether the defendant had constructive possession.” State v. Voll, 2012-Ohio-3900, ¶ 19 (3d Dist.).

The Curious Theory of Spontaneous Drug Displacement and Requiring the Court to Disbelieve the Defendant’s Own Words

Consequently, since it is the only element that he challenges, we will address the weight of the evidence supporting whether Mr. Stackhouse possessed the drugs. Here, Mr. Stackhouse points to the evidence that the violent collision could have dislodged the drugs from a concealed part of the vehicle, meaning he never knowingly possessed them. He further contends that his on-scene admission was a false statement made only to protect Ms. Iannantuono, whose own drug history and failure to testify at trial (even though Mr. Stackhouse subpoenaed her to testify) suggest that the contraband belonged to her.

Mr. Stackhouse Did the State the Courtesy of Testifying Against Himself

Decisively, the evidence presented at trial reflects that Mr. Stackhouse actually possessed the drugs because he admitted to Officer Jared Lindig of the Fostoria Police Department that the drugs were his. Accord State v. Pollard, 2025-Ohio-1706, ¶ 24 (11th Dist.). Indeed, Officer Lindig testified at trial that he was dispatched to the scene of a single vehicle accident where he found Mr. Stackhouse unresponsive and slumped across the front seat of the damaged vehicle. According to Officer Lindig, as he approached the passenger side of the vehicle, he immediately saw two bags of a white powdery substance in plain view on the passenger seat, in the proximate location where Mr. Stackhouse was found. After rousing Mr. Stackhouse by shaking him, Officer Lindig observed Mr. Stackhouse move his hands toward the area where the suspected drugs were located. He further testified that, after being read his Miranda rights and asked about the packages, Mr. Stackhouse first asked, “how much”—which Officer Lindig understood to be a question about the quantity of drugs found—and then admitted, “It’s mine.” Officer Lindig also testified that Mr. Stackhouse admitted to using cocaine earlier that evening.

AI created image of the incident.

From It’s Mine to I Was Just Groggy

Nevertheless, Mr. Stackhouse contends that his on-scene statements should be given little weight because he was disoriented from the accident and had just been woken up. Specifically, he argues that his question of “how much” was one of genuine confusion, not an admission of knowledge. He further asserts that his confession should have been discounted because he later revoked it, testifying that he was falsely “taking the hit” to protect Ms. Iannantuono.

[T]he jury was free to disbelieve his explanation.

In this case, the jury was presented with two competing narratives. Specifically, the jury was free to credit, based on Mr. Stackhouse’s explicit admission of ownership, along with the drugs’ placement in plain view and his admission of recent drug use, that he actually possessed the contraband. Alternatively, the jury was free to accept Mr. Stackhouse’s testimony that he was merely “taking the hit” for Ms. Iannantuono. However, the jury was free to disbelieve his explanation, just as it is free to reject any defendant’s claim that another person is responsible for contraband. Compare Ruby, 2002-Ohio-5381, at ¶ 44 (2d Dist.) (holding that Ruby’s conviction was not against the manifest weight of the evidence where the jury, as the arbiter of witness credibility, was free to disbelieve the defendant’s claim that a known drug dealer who was also in the vehicle was responsible for the contraband).

[T]he jury afforded more weight to the State’s evidence than Mr. Stackhouse’s version of events.

Furthermore, the jury observed Mr. Stackhouse’s testimony and was made aware of Ms. Iannantuono’s refusal to testify. “‘“A verdict is not against the manifest weight of the evidence because the [jury] chose to believe the State’s witnesses rather than the defendant’s version of the events.”’” State v. Missler, 2015-Ohio1076, ¶ 44 (3d Dist.), quoting State v. Bean, 2014-Ohio-908, ¶ 15 (9th Dist.), quoting State v. Martinez, 2013-Ohio-3189, ¶ 16 (9th Dist.). Thus, that the jury afforded more weight to the State’s evidence than Mr. Stackhouse’s version of events does not render his convictions against the manifest weight of the evidence.

Conclusion and Holding

For these reasons, we conclude that the trier of fact did not lose its way in determining that the evidence that Mr. Stackhouse did not possess the drugs is not more compelling and credible than the evidence that he committed the offenses of which he was convicted. Therefore, Mr. Stackhouse’s convictions are not against the manifest weight of the evidence.

Mr. Stackhouse’s first assignment of error is overruled.

Note: There were two additional appeals that focused on the court exclusion of Ms. April Ms. Iannantuono’s criminal history and Mr. Stackhouse’s sentencing.  Both appeals were also denied but are not evaluated in this article.

Information for this article was obtained from State v. Stackhouse, 2025 – Ohio – 5464.

State v. Stackhouse, 2025 – Ohio – 5464 was issued by the Third District Appellate Court and is binding in the following Ohio Counties: Allen, Auglaize, Crawford, Defiance, Hancock, Hardin, Henry, Logan, Marion, Mercer, Paulding, Putnam, Seneca, Shelby, Union, Van Wert and Wyandot.

Lessons Learned

    1. Plain View Doctrine – On June 4, 1990 the U.S. Supreme Court issued Horton v. California, 496 U.S. 128 (1990) that established the three part Plain View Doctrine: 1) Law must be legally on the premises from where the observation is made; 2) Law enforcement must not violate the Fourth Amendment to make the observation and 3) Incriminating nature of the item must be immediately apparent. In this case Officer Lindig observed the cocaine on the seat next Mr. Stackhouse when Mr. Stackhouse was slumped over the wheel at the scene of a motor vehicle accident. Consequently, the observation by Officer Lindig comported to the Horton three-part Plain View test.
    2. Post Miranda Statements – When a defendant says “it’s mine,” asks “how much,” and admits recent drug use, appellate courts are unlikely to treat those statements as meaningless simply because the defendant later regrets them or offers a more convenient explanation at trial. Note that Mr. Stackhouse never challenged his voluntary waiver of his Miranda Rights.  A suspect must provide a 1) Knowingly, 2) Voluntarily and 3) Intelligent waiver to consent to an interview.  See Miranda v. Arizona, 384 U.S. 436 (1966). This fact alone is a testament that the defense observed no legal wiggle room to the professional work of Fostoria Police Officer Jared Lindig.
    3. The Not Mine Defense – Pointing to another person’s criminal history or suggesting ownership by someone who conveniently does not testify is not enough to overcome direct admissions and circumstantial evidence. Courts consistently hold that juries may reject “someone else did it” defenses, particularly when unsupported by contemporaneous evidence. Here, the girlfriend’s non-testimony and subpoena refusal hurt the defense more than helped. This is why capturing the suspect’s statements at the scene is very important.  In the moment Mr. Stackhouse’s statements may not have seemed critical, but these inculpatory statements had serious impact on his guilt, conviction, sentencing and appeal defense.
    4. Pre-Sent Arms! Fostoria Police Officer Jared Lindig and the Seneca County Prosecutor’s Office should be highly commended for their work on the investigation, conviction and appeal defense of Mr. Stackhouse. Well done!

Does your agency train on Vehicle Searches and the Plain View Doctrine?

Don’t fail your training.

Don’t let your training fail you!

Be safe, smart and objectively reasonable!

Robert H. Meader Esq.