City of Parma v. Treanor, 117 N.E.3d 970

Treanor was charged with two counts of aggravated menacing and one count of domestic violence after an incident in December 2016.
Treanor’s son, Seth, and a friend, Andrew, arrived at Treanor’s home late at night; Seth (intoxicated) confronted Treanor, who was asleep with beer cans and a loaded firearm nearby.
A physical/verbal altercation ensued; Seth cut his finger, went to the kitchen, and Andrew (a stranger to Treanor) was present; Treanor retrieved a firearm and told them to leave.
Witnesses conflicted: Seth and Andrew testified Treanor threatened to shoot them (and may have pointed the gun); Treanor testified he pointed the gun in the air, did not point at anyone, and ordered them out because he felt threatened.
At trial Treanor requested jury instructions on self-defense and the castle doctrine; the court denied the requests and the jury convicted him on all counts.
On appeal the Eighth District held the trial court abused its discretion by refusing the requested self-defense and castle-doctrine instructions and reversed and remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by refusing to instruct the jury on self-defense and the castle doctrine	The City: instructions were inapplicable because Treanor only threatened force and did not use deadly force (no discharge)	Treanor: testimony raised sufficient evidence that he reasonably and honestly believed deadly force (or threat thereof) was necessary to repel an imminent threat inside his home; castle doctrine applies	Reversed — the trial court abused its discretion. Sufficient evidence existed to warrant self-defense and castle-doctrine instructions; error requires new trial

State v. Wolons, 44 Ohio St.3d 64, 541 N.E.2d 443 (Ohio 1989) (standard for reviewing refusal to give requested jury instructions)
State v. Abner, 55 Ohio St.2d 251, 379 N.E.2d 228 (Ohio 1978) (factual determinations about self-defense are for the jury)
State v. Comen, 50 Ohio St.3d 206, 553 N.E.2d 640 (Ohio 1990) (trial court must give all instructions relevant and necessary for the jury)
State v. Nelson, 36 Ohio St.2d 79, 303 N.E.2d 865 (Ohio 1973) (correct, pertinent jury instructions must be given when appropriate)
State v. Melchior, 56 Ohio St.2d 15, 381 N.E.2d 195 (Ohio 1978) (defendant must introduce evidence sufficient in nature and quality to raise an affirmative defense)
State v. Robinson, 47 Ohio St.2d 103, 351 N.E.2d 88 (Ohio 1976) (view evidence in light most favorable to defendant when determining instruction sufficiency)
State v. Williford, 49 Ohio St.3d 247, 551 N.E.2d 1279 (Ohio 1990) (self-defense privilege limited to force reasonably necessary to repel an attack)
State v. Koss, 49 Ohio St.3d 213, 551 N.E.2d 970 (Ohio 1990) (self-defense requires both honest and objectively reasonable belief of imminent harm)
State v. Thomas, 77 Ohio St.3d 323, 673 N.E.2d 1339 (Ohio 1997) (discussing objective and subjective components of self-defense)