State v. Archer, 2014 Ohio 1207

Dispute between neighbors involving Archer and Yeatts; Archer had a three-year hostile relationship with neighbors.
On April 15, 2011, Yeatts and neighbor Keffer were at a street mailbox when Archer horned past them.
Yeatts reported being upset and Joseph confronted Archer; threats were exchanged.
Joseph retrieved a pistol from a rental truck, fearing Archer; Archer drove off.
Video surveillance and multiple witnesses documented threats; Archer was charged with one count of aggravated menacing.
Jury found Archer guilty; he appeals raising three assignments of error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict aggravated menacing	Archer argues the State failed to prove knowledge.	State contends evidence shows Archer knew his threats could be heard or relayed.	Sufficient evidence; denial of Crim.R. 29 affirmed.
Plain error in not instructing self-defense and lesser offense	Archer claims plain error requiring sua sponte instructions.	State argues no plain error given lack of self-defense evidence.	No plain error; instructions not warranted.
Ineffective assistance of counsel	Archer asserts counsel failed to seek severance, self-defense, lesser offenses, and objections.	State contends trial strategy was reasonable; no prejudice shown.	No ineffective assistance; arguments rejected.

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for sufficiency of evidence; belief beyond reasonable doubt)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (definition of sufficiency; reviewing court views evidence in light most favorable to the state)
State v. Long, 53 Ohio St.2d 91 (Ohio 1978) (plain error standard under Crim.R. 52(B))
State v. Carter, 89 Ohio St.3d 593 (Ohio 2000) (instruction on lesser-included offenses)
State v. Poole, 33 Ohio St.2d 18 (Ohio 1973) (self-defense affirmative defense burden of proof)
State v. Knoble, 2008-Ohio-5004 (Ohio 2008) (threats may be overheard or relayed; no requirement that threat be uttered to target)