State v. Baskerville, 2017 Ohio 4050

Background

Defendant Deandre Baskerville stabbed an acquaintance in the neck outside a mall in August 2015; the victim died from the wound. Baskerville admitted stabbing the victim but claimed self-defense.
Baskerville fled the scene, sanitized his car, burned his clothes, disposed of the knife, and left Ohio; he was arrested in West Virginia about a month later.
Indicted on aggravated murder, two counts of murder, felonious assault (by deadly weapon), and carrying a concealed weapon; jury acquitted on aggravated murder but convicted on the remaining counts.
At trial Baskerville testified and disclosed prior convictions; State probed his prior weapons conviction and circumstances on cross-examination.
Evidence included eyewitness testimony, mall and autopsy photographs, DNA consistent with the victim in Baskerville’s car, the victim’s fatal stab wound (trachea, jugular), and Baskerville’s post-incident conduct and jail statements.
Baskerville appealed raising evidentiary, instructional, prosecutorial-misconduct, sufficiency/manifest-weight, and ineffective-assistance claims; the Ninth District affirmed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Baskerville)	Held
Admissibility of prior-conviction details on cross-exam	Cross-exam of defendant about factual circumstances of prior weapons charge and probation status was permissible to probe credibility, intent, and rebut inferences defendant opened on direct	Admission of detailed prior-act facts was irrelevant, prejudicial, and violated Evid.R. 404(B)	Court: No abuse of discretion. Defendant opened door; details were relevant to intent/absence of accident and probative value not substantially outweighed by prejudice.
Manifest weight/self-defense	State: evidence (face-to-face argument, opportunity to retreat, flight, evidence destruction, learned self-defense tale in jail) supports murder/felonious assault verdicts	Baskerville: acted in self-defense; victim reached for a weapon and had a knife by his body	Court: Jury did not lose its way. Even if imminent danger existed, jury could find duty to retreat violated; other evidence (flight, cleanup, equivocal testimony) supports conviction.
Admission of crime-scene and autopsy photographs	Photos aided jurors in understanding wounds and scene; not needlessly cumulative or unduly gruesome	Photographs were inflammatory, cumulative, and prejudicial; plain error in admitting them without objection	Court: No plain error. Mall photos not of bodies; autopsy photos each served distinct evidentiary purposes. Admission proper.
Jury instructions & lesser-included offenses	Properly instructed on self-defense; no evidence supported voluntary manslaughter/aggravated assault (sudden passion) or involuntary manslaughter (defense counsel waived)	Instruction on "at fault" was confusing; court should have instructed on involuntary/voluntary manslaughter and aggravated assault	Court: No reversible error. Any defect in "at fault" instruction was not outcome-determinative; no evidentiary basis for voluntary manslaughter/aggravated assault; involuntary manslaughter instruction waived by counsel.

Key Cases Cited

State v. Williams, 134 Ohio St.3d 521 (2012) (sets three-step Evid.R. 404(B) analysis and balancing standard)
State v. Morris, 132 Ohio St.3d 337 (2012) (admissibility-of-other-acts reviewed for abuse of discretion)
State v. Goff, 128 Ohio St.3d 169 (2010) (elements of self-defense; duty to retreat and burden to prove self-defense)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest-weight standard; appellate court as thirteenth juror)
State v. Otten, 33 Ohio App.3d 339 (1986) (framework for manifest-weight review)
State v. Maurer, 15 Ohio St.3d 239 (1984) (gruesome photographs not per se inadmissible; relevance for illustrating testimony)
State v. Barnes, 94 Ohio St.3d 21 (2002) (plain-error doctrine in criminal cases)
State v. Jackson, 22 Ohio St.3d 281 (1986) (self-defense elements are cumulative)