Ruling in State v. Brown affirms that defendants can be tried in any county where their associates commit enterprise-related crimes, even without direct involvement.
The Supreme Court of Ohio ruled that a defendant can be prosecuted in a county even though he never personally conducted criminal acts there.
The decision hinged on the actions of a cocaine distributor tied to the defendant and his associates who repeatedly purchased cocaine on credit in Lucas County and resold it in Henry County. The Court found that this arrangement made the distributor part of the same criminal enterprise and as a result subject to prosecution in a county where the distributor had never set foot.
Key Points from the Decision:
- Venue is proper in any county where any member of a criminal enterprise commits enterprise-related acts.
- “Fronting” drugs for resale creates a conspiratorial link between supplier and reseller.
- Ohio’s RICO statute applies broadly, capturing not only core members but also those who knowingly advance the enterprise’s goals.
Public Impact
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This landmark ruling strengthens law enforcement’s ability to dismantle criminal networks that operate across county lines. It prevents gang leaders from insulating themselves geographically while profiting from out-of-county sales. Prosecutors and investigators now have clearer authority to pursue enterprise cases wherever the network’s reach extends, helping protect communities from the spread of organized drug trafficking.
Case Reference: State v. Brown, 2025-Ohio-2804 (Supreme Court of Ohio, August 12, 2025).
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