State v. Bloodworth, 2022 Ohio 1899

On Sept. 23, 2019, at Lebanon Correctional Institution, inmate Ronald Bloodworth stabbed his cellmate, Michael Hammett, multiple times in the face and head with a sharpened wooden Scrabble tile holder (a shank); Hammett required surgery and suffers lasting vision problems.
Bloodworth was serving time for prior murder and related convictions when indicted (July 13, 2020) on: two counts of felonious assault (R.C. 2903.11(A)(1) and (A)(2)) and one count of possession of a deadly weapon while under detention (R.C. 2923.131(B)).
Evidence: Hammett’s testimony, security footage of movements in the dayroom, Trooper and investigator testimony, recovery of the shank where Bloodworth said it would be, and Bloodworth’s prior statements admitting he found and sharpened the piece and used it.
Bloodworth testified he acted in self-defense, claiming Hammett first swung and possessed the shank; he also admitted to earlier inconsistent statements (saying the shank was his) which he said were lies to avoid being labeled a snitch.
Jury rejected self-defense, convicted on all counts; court merged allied felonies, sentenced Bloodworth to an indefinite Reagan Tokes term of 4–6 years (concurrent with weapons count).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bloodworth)	Held
Whether trial court erred by not instructing jury that self-defense applies to possession-of-deadly-weapon charge	Self-defense instruction not required because possession offense does not involve use of force against another	A self-defense instruction was warranted and preserved by filing a Notice of Affirmative Defense	No error; possession statute does not involve "use of force," Crim.R.30 waiver applies, plain-error review fails — instruction unnecessary
Sufficiency/manifest weight of the evidence for felonious assault and possession convictions	Evidence (victim, investigators, recovery of shank, defendant’s prior admissions) proves elements and disproves self-defense beyond a reasonable doubt	Evidence is insufficient; jury should have accepted defendant’s self-defense account and inconsistencies show reasonable doubt	Convictions are supported by sufficient evidence and not against manifest weight; jury reasonably rejected self-defense
Whether the Reagan Tokes indefinite-sentencing scheme is unconstitutional	Reagan Tokes is constitutional as previously upheld by this court	Scheme violates right to jury trial, due process, and separation of powers	Court rejects constitutional challenges; follows controlling 12th Dist. precedent upholding Reagan Tokes

State v. Lynn, 129 Ohio St.3d 146 (plain-error and Crim.R. 30 objection rule)
State v. Barnes, 94 Ohio St.3d 21 (plain-error standard explanation)
State v. Biros, 78 Ohio St.3d 426 (plain-error outcome requirement)
State v. Jenks, 61 Ohio St.3d 259 (sufficiency-of-the-evidence standard)
State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight standard)
State v. Williford, 49 Ohio St.3d 247 (proportionality of force in self-defense)