State v. Baisden

Ohio Court of Appeals·Decided August 10, 2026·No. 24CA15·Published

Opinion

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT JACKSON COUNTY

STATE OF OHIO, :

: Case No. 24CA15

Plaintiff-Appellee, :

:

v. :

: DECISION AND JUDGMENT BRYSON BAISDEN, : ENTRY :

Defendant-Appellant. :

: RELEASED: 08/10/2026

APPEARANCES:

Christopher Pagan, Middletown, Ohio, for appellant. Trenton Douthett, Jackson County Prosecuting Attorney, for appellee.

Wilkin, J.

{¶1} This is an appeal of a Jackson County Court of Common Pleas judgment entry in which Bryson Baisden (“Baisden”) was convicted after a jury trial of aggravated possession of drugs, receiving stolen property, and tampering with evidence. On appeal, Baisden contends: 1) his conviction for tampering with evidence was contrary to law because the State presented insufficient evidence of an essential element of the offense; and 2) the trial court imposed an unlawful consecutive sentence. After reviewing the parties’ arguments, the record, and the applicable law, we find Baisden’s assignments of error to lack merit and therefore affirm the trial court. However, we remand the case to the trial court for the limited purpose of correcting the sentencing entry.

BACKGROUND

{¶2} In October 2021, M.L. reported someone had stolen his 2013 Arctic Cat 700 four-wheeler, which was later entered into a statewide database as a stolen vehicle. Shortly after, on November 2, 2021, while employed by the Jackson County Sheriff’s Office, Deputy Leif Smith (“Smith”) responded to a call that Baisden had been riding the stolen four-wheeler. Smith knew Baisden from past encounters. At the time Smith received the information, he was not “on duty”; however, he drove his cruiser to investigate and found Baisden with the stolen four-wheeler at the old drive-in on State Route 93, between Glenroy and Coalton in Jackson County. When Smith questioned Baisden, Baisden said he obtained the four-wheeler (which had its original ignition punched out and two wires exposed from hotwiring) from a man named Blazer. Not only did Baisden say he knew the four-wheeler was stolen, the four-wheeler had also obviously been painted with the factory paint showing through.

{¶3} Smith detained Baisden. Before patting Baisden down, Smith asked Baisden if he had anything illegal on his person. At that point, Baisden removed a hypodermic syringe from his pocket. Once Baisden produced the hypodermic needle, Smith believed that Baisden might have an illegal substance on his person. Smith then advised Baisden to turn around so Smith could perform the pat-down.

{¶4} As Baisden turned around, he bent forward and made a tossing motion--then Smith heard the noise of an object striking something metal. Once Smith completed the pat-down, he placed Baisden in his cruiser. Then Smith

went back to retrieve the object in the area where Baisden had thrown it and discovered a pill bottle containing a crystalline substance. Smith believed the substance to be methamphetamine (which later testing confirmed to be .48 grams of methamphetamine). When Smith confronted Baisden about the object, Baisden said, “damn.”

{¶5} On May 15, 2023, a Jackson County Grand Jury returned an indictment against Baisden for three counts: aggravated possession of drugs (methamphetamine), a fifth-degree felony, in violation of R.C. 2925.11(A) and (C)(1)(a); receiving stolen property, a fourth-degree felony in violation of R.C. 2913.51(A) and (C); and tampering with evidence, a third-degree felony in violation of R.C. 2921.12(A)(1).

{¶6} On July 10, 2023, the trial court found Baisden incompetent to stand trial but restorable and remanded him to a psychiatric hospital for treatment. After Baisden was restored to competency, the case proceeded to a jury trial on June 10, 2024. At the conclusion of the State’s case, Baisden made a Crim.R. 29(A) motion for acquittal. The trial court overruled the motion. The jury subsequently found Baisden guilty of all counts.

{¶7} The trial court set the hearing for sentencing on a separate date, and Baisden failed to appear. When Baisden did appear, the trial court imposed maximum consecutive sentences, for an aggregate 66-month term, set forth in an entry dated September 20, 2024.

{¶8} Baisden submitted a notice of appeal with two assignments of error.

ASSIGNMENTS OF ERROR

I. THE CONVICTION FOR F3 TAMPERING WAS CONTRARY TO LAW.

II. THE TRIAL COURT IMPOSED AN UNLAWFUL CONSECUTIVE SENTENCE.

FIRST ASSIGNMENT OF ERROR

{¶9} In his first assignment of error, Baisden contends that his conviction for tampering with evidence was contrary to law because the State failed to present sufficient evidence of each element of the offense. Specifically, Baisden asserts the State failed to prove he knew that the deputy was acting officially when the deputy investigated the concealed methamphetamine.

{¶10} The State acknowledges that the deputy investigating the case was off duty at the time of the offense; however, contends that the deputy was in uniform and driving his police cruiser at the time when he encountered Baisden so there was no indication that Baisden even knew the deputy was off duty. Further, the State points to several facts that show Baisden knew an official investigation was underway when he concealed the methamphetamine, and also distinguishes the cases cited by Baisden on appeal.

A. Law.

1. Standard of Review

{¶11} “In general, a claim of insufficient evidence invokes a due process concern and raises the question of whether the evidence is legally sufficient to support the verdict as a matter of law.” State v. King, 2022-Ohio-4616, ¶ 22 (4th Dist.), citing State v. Schroeder, 2019-Ohio-4136, ¶ 59 (4th Dist.); State v.

Thompkins, 78 Ohio St.3d 380, 386 (1997). Thus, “[w]hether the evidence is legally sufficient to sustain a conviction is a question of law that this court reviews de novo.” State v. Brown, 2025-Ohio-2804, ¶ 16, citing State v. Groce, 2020- Ohio-6671, ¶ 7. Viewing the evidence in the light most favorable to the prosecution the court asks whether “ ‘ “any rational trier of fact could have found the essential elements of the crime proved beyond a reasonable doubt.” ’ ” Id., quoting State v. Dean, 2015-Ohio-4347, ¶ 150, quoting State v. Jenks, 61 Ohio St.3d 259 (1991), paragraph two of the syllabus. Accordingly, “[t]he appropriate standard of review for a sufficiency-of-the-evidence challenge is ‘whether, if believed, the evidence can sustain the verdict as a matter of law.’ ” Id. at ¶ 17, quoting State v. Richardson, 2016-Ohio-8448, ¶ 13.

{¶12} In proving its case, the State may rely on either direct or circumstantial evidence. “Circumstantial evidence and direct evidence inherently possess the same probative value.” State v. Barnes, 2020-Ohio-3943, ¶ 24 (4th Dist.), citing Jenks, paragraph one of the syllabus. In fact, “all courts have concluded that a defendant may be convicted solely on the basis of circumstantial evidence.” State v. Burns, 2025-Ohio-5442, ¶ 26 (4th Dist.), citing State v. Nicely, 39 Ohio St.3d 147, 151 (1988); State v. Anderson, 2018-Ohio- 2013, ¶ 40 (4th Dist.). Circumstantial evidence is defined as “ ‘[t]estimony not based on actual personal knowledge or observation of the facts in controversy, but of other facts from which deductions are drawn, showing indirectly the facts sought to be proved.’ ” State v. Meddock, 2017-Ohio-4414, ¶ 54 (4th Dist.),

quoting State v. Nicely, 39 Ohio St. 3d at 150, (1988), quoting Black's Law Dictionary (5th Ed. 1979).

2. Tampering with Evidence

{¶13} Baisden challenges his conviction for tampering with evidence.

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