State v. Chappell

*377{¶ 1} This appeal involves the construction of the term “criminally” in R.C. 2923.24(A), which proscribes the possession of criminal tools, i.e., the possession of “any substance, device, instrument, or article, with purpose to use it criminally.” Appellant, the state of Ohio, asserts that the plain meaning of the word “criminally” embraces all criminal purposes, including the purpose to violate federal as well as state or municipal law.1

{¶ 2} Conversely, appellee, Welton Chappell, contends that the state cannot use intended violations of federal criminal statutes or municipal ordinances to…