2024 Ohio 1693
Ohio Ct. App.2024Background
- Payton Campbell was convicted following a jury trial for attempted murder and felonious assault with firearm specifications stemming from a shooting outside the Medusa nightclub in Cleveland, Ohio in March 2022.
- The incident began with an ongoing feud between two rap artists (Finley and Collins), escalated to a physical altercation, and culminated in multiple parties being shot, including alleged bystanders.
- Campbell, an Atlanta resident and Finley’s boyfriend, fired multiple shots during the chaotic fight; victims included Bianca Smith (multiple injuries), Quasean Townsend (foot wound), and Fatihah Majid (grazed by bullet). Collins was also shot but Campbell was acquitted of charges involving her.
- The defense argued self-defense and sought related jury instructions, including transferred intent for self-defense as applied to injuries suffered by bystanders.
- The trial court sentenced Campbell to an aggregate term of 14 to 16.5 years, after convicting him on multiple counts and imposing consecutive firearm enhancements.
- On appeal, Campbell challenged the verdict on grounds of manifest weight and sufficiency of the evidence, adequacy of jury instructions, Confrontation Clause violations, evidence authentication, and legality of consecutive firearm specifications.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Verdict against manifest weight; self-defense | Evidence shows Campbell not acting in self-defense; jury could credit state’s witnesses | Campbell was defending himself and Finley; shooting justified | Verdict not against weight; jury credited state’s evidence |
| Failure to instruct on transferred intent/self-defense | Not required; transferred intent self-defense unsettled in district | Lack of instruction prejudiced self-defense argument for bystanders | No reversible error; instruction would not have changed outcome |
| Sufficiency of evidence on intent and causation | Victims’ and video testimony established purpose/knowledge; transferred intent for bystanders | State did not prove Campbell knowingly caused harm/risk to Smith/bystanders | Sufficient evidence supported convictions |
| Admission/authentication of Townsend evidence (Confrontation) | Medical records/statements for treatment are admissible; video identified by nurse | Out-of-court statements violated confrontation rights; video not authenticated | No violation; records/treatment admissions standard met; authentication sufficient |
| Consecutive firearm specifications | Permissible under R.C. 2929.14(B)(1)(g) for most serious offenses | All offenses were part of same act; only one firearm term allowed | Sentencing proper under statutory exception |
Key Cases Cited
- State v. Wilks, 154 Ohio St.3d 359 (Ohio 2018) (standard for reviewing manifest weight of the evidence claims)
- State v. Messenger, 171 Ohio St.3d 227 (Ohio 2022) (burden of persuasion in self-defense cases)
- State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for sufficiency of the evidence)
- State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (elements and law of self-defense)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause and testimonial hearsay)