Michael Horton v. Warden, Trumbull Correctional, 498 F. App'x 515

Horton was charged in Stark County with murder, discharging a firearm in a motor vehicle, and later pleaded guilty to having a weapon while under a disability; trial proceeded on the two remaining counts.
Horton moved for a jury instruction on self-defense, which the trial court denied for lack of evidence to support it.
The trial court instructed the jury on murder with a standard purpose-to-kill framework and rejected other defenses, including self-defense.
The Ohio Court of Appeals affirmed, concluding Horton failed to present sufficient evidence for a self-defense instruction.
Horton filed a federal habeas corpus petition under 28 U.S.C. § 2254; the district court granted relief on the due-process theory that his defense was improperly denied, and the Warden appealed for reversal.
The Sixth Circuit reversed the district court, holding the state court’s adjudication did not unreasonably apply clearly established federal law regarding self-defense instructions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Horton’s due process claim is cognizable on habeas review.	Horton asserts denial of the right to present a complete defense.	Warden argues it concerns a state-law question, not federal due process.	Cognizable under § 2254(d) as a due-process claim.
Whether the Ohio court’s denial of a self-defense instruction involved an unreasonable application of clearly established federal law.	Horton contends settled law requires a self-defense instruction when evidence supports it.	Warden contends the state court did not apply the law unreasonably to the facts.	Not unreasonable; fairminded jurists could disagree on sufficiency of evidence.
Whether the evidence was sufficient under Ohio law to raise self-defense as a jury question.	Evidence could support a reasonable belief of imminent danger and duty to retreat was not clearly satisfied.	Evidence did not convincingly show an imminent threat or necessity for deadly force.	District court erred in finding unreasonable application; habeas relief denied on this ground.

Trombetta v. California, 467 U.S. 479 (Supreme Court 1984) (due process right to present a complete defense; no prejudice from missing evidence necessarily)
Mathews v. United States, 485 U.S. 58 (Supreme Court 1988) (jury instruction sufficiency when defense is recognized and supported by evidence)
Taylor v. Withrow, 288 F.3d 846 (6th Cir. 2002) (due process right to self-defense instruction when evidence supports it)
Harrington v. Richter, 131 S. Ct. 770 (Supreme Court 2011) (AEDPA review; unreasonable application standard for state-court decisions)
Williams v. Taylor, 529 U.S. 362 (Supreme Court 2000) (definition of clearly established federal law for § 2254(d))