R.C. 2925.03(A) Interpretation
In State v. Cabrales, 118 Ohio St.3d 54, 2008 Ohio 1625, 886 N.E.2d 181, the Ohio Supreme Court held that trafficking in a controlled substance under R.C. 2925.03(A)(2) and possession of that same substance were allied offenses of similar import pursuant to R.C. 2941.25(A) because, "commission of the first offense trafficking necessarily resulted in commission of the second offense of possession." Id. at P30.
In addition, the court found that the defendant in Cabrales was found to have "trafficked and possessed the marijuana with a single animus: to sell it" and could not be convicted of both offenses. Id. at P31.