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State v. Taylor
Citations: 534 N.E.2d 376; 41 Ohio App. 3d 57; 1987 WL 13301; 1987 Ohio App. LEXIS 10753Docket: No. 86AP-1033
Court: Ohio Court of Appeals; June 25, 1987; Ohio; State Appellate Court
An appeal has been filed by the defendant following a judgment from the common pleas court, which found him guilty of violating R.C. 2925.11, a statute that criminalizes the possession of controlled substances not in their original containers, regardless of prescription. The defendant was arrested by an off-duty police officer who discovered forty-six prescription drug tablets during an inventory search. The case was tried on stipulated facts, including testimony that the defendant was narcoleptic and had been prescribed Ritalin, one of the drugs found during the arrest. The defendant claimed he removed some tablets from the original prescription bottle and stored them in aluminum foil for a weekend trip, but the court did not accept this as a valid defense. On appeal, the defendant raised three assignments of error: (1) the trial court's finding of guilt despite the defendant having a prescription was erroneous; (2) the trial court failed to consider the defendant's affirmative defense; and (3) the application of R.C. 2925.11 was incorrect as it criminalizes actions that should be legal for prescription drug users. The court noted that, while the defendant technically violated the statute, strict interpretation leads to an unreasonable outcome, as it would criminalize the necessary act of taking medication outside its original container. The court emphasized that legislative intent should yield a just result and that statutes must be interpreted to avoid absurd consequences. Consequently, it concluded that the interpretation of R.C. 2925.11(B) should account for the reasonableness of the time elapsed between taking the medication and removing it from the container, considering relevant factors such as dosage, frequency, and quantity. The court found that literal compliance with the statute was impractical and mandated a reversal of the conviction. A one-day supply of a prescribed drug in a pillbox is typically considered reasonable, while a three-day supply during a shopping trip likely is not. Each case under R.C. 2925.11 must be evaluated based on its specific facts. The court sustained the defendant's first and third assignments of error, recognizing a prima facie violation of the drug abuse statute but finding that the trial court did not properly consider the circumstances surrounding the violation. The second assignment of error, concerning the trial court's refusal to provide an instruction on an affirmative defense to R.C. 2925.11, was deemed premature and not addressed due to the resolution of the first and third assignments. Consequently, the court reversed the common pleas court's judgment and remanded the case for further proceedings. Judges Bowman and Brogan concurred, with Brogan sitting by assignment from the Second Appellate District.