## Facts

- Charles Eddie Conley was convicted in an Ohio trial court of selling LSD, a hallucinogen.
- At trial, the State offered **Exhibit 1**, a brown evidence envelope containing **18 orange pills** wrapped in a cellophane sack from a cigarette pack.
- **Jenkins**, an informant, testified that Conley sold Jenkins orange pills packaged in a cellophane sack and that Jenkins gave the pills to a police officer.
- The **police officer** testified that the officer received the cellophane-wrapped pills from Jenkins and delivered them to **Captain Severns**.
- Jenkins and the officer each testified that Exhibit 1 appeared to be the same pills they handled.
- **Captain Severns** testified that the brown envelope in Exhibit 1 was the property envelope Severns used to store the cellophane-wrapped pills, labeled as containing “20 orange sunshine pills in a cellophane wrapper,” and that Severns delivered the envelope to an **unidentified man** at the crime laboratory.
- **Rector**, a chemist at the crime laboratory, testified about the lab’s routine evidence-handling process: an evidence coordinator assigns a case number to material brought in for testing and places it in the proper file.
- Rector testified that when he retrieved the brown envelope from a filing cabinet, it bore a laboratory case number. Rector initialed the envelope and the cellophane wrapper, used **two pills** for testing, then sealed the remaining pills and packaging in an envelope stored in a locked area until trial.
- Conley appealed, arguing the State failed to establish an adequate **chain of custody** because the person at the laboratory who received the envelope from Severns did not testify.

## Issues

1. Whether the trial court erred by admitting the pills into evidence when the State did not call as a witness the unidentified laboratory recipient who received the evidence envelope from Captain Severns.

## Decision

- The appellate court **affirmed** Conley’s conviction.
- The court held that the State made a sufficient showing that Exhibit 1 was the same evidence obtained in the controlled buy and that it had not been materially altered, even though one handler (the unnamed laboratory recipient) did not testify.
- The court treated the gap in testimony as affecting the **weight** of the evidence rather than requiring exclusion where the surrounding testimony and laboratory procedures provided reasonable assurance of identity and integrity.

## Legal Principles

- Physical evidence is admissible when the proponent provides a foundation establishing a reasonable assurance that the item is what it is claimed to be and is in substantially the same condition as when obtained.
- The State is not required to produce testimony from every person who may have handled an item of evidence if other testimony and standard custodial procedures sufficiently identify the exhibit and account for its safekeeping.
- A break or uncertainty in the chain of custody generally goes to the weight of the evidence for the factfinder, not to admissibility, absent a showing of material tampering or substitution.

## Conclusion

State v. Conley upheld the admission of LSD pills and affirmed a drug-sale conviction where the State identified the exhibit through witness recognition and laboratory handling testimony, and the absence of testimony from one laboratory recipient did not require exclusion of the evidence.


State v. Conley, 288 N.E.2d 296 (1971)