State v. Carosiello, 2017 Ohio 8160

Background

Defendant Nicolas Carosiello, a known drug dealer, learned a group intended to burglarize his house; he took steps to make the house appear empty, moved cars to a field, hid drugs and cash, and maintained phone contact with an intermediary (Johnny).
Defendant and several acquaintances concealed themselves in a field behind the house armed with firearms; defendant waited in a bedroom with a .22 handgun when the victims attempted entry through a window.
As the victim (Holly, defendant’s estranged wife) was climbing through the window, defendant fired a single shot that struck her between the eyes; he then fired additional shots into the yard.
Defendant initially gave multiple false statements to police, later admitted to shooting but claimed he fired at a “shadow”; several witnesses (including accomplices who later pleaded guilty) testified defendant had lured the group and aided entry.
A jury convicted defendant of aggravated murder (with firearm specifications), tampering with evidence, and possession offenses; the trial court imposed consecutive sentences including life without parole for aggravated murder. Defendant appealed.

Issues

Issue	State's Argument	Carosiello's Argument	Held
Sufficiency of evidence of "prior calculation and design" for aggravated murder	Evidence showed planning: luring the group by making the house appear empty, arming himself, concealing with accomplices, directing others not to come, and aiding entry — supporting a rational juror’s finding of premeditation	Evidence at most showed preparation to have friends present and a desire to catch burglars; no proof he planned to kill Holly or deliberated beyond a momentary decision	Court held evidence (largely circumstantial) was sufficient to permit a rational juror to find prior calculation and design under totality of circumstances; assignment overruled
Scope and rebuttal of the "castle doctrine" presumption (R.C. 2901.05(B)(1))	The state can rebut the statutory presumption by proving defendant did not satisfy elements of traditional self-defense (e.g., he was at fault, lacked bona fide fear)	Defendant contended the castle-doctrine presumption is standalone and can be rebutted only by proof the victim had lawful entry; defendant’s conduct is irrelevant	Court rejected defendant’s reading; held the presumption does not eliminate traditional self-defense elements and the state may rebut by showing defendant was at fault or lacked reasonable belief of imminent harm
Manifest weight of the evidence (self-defense claim)	Witness testimony, phone records, physical evidence, admissions, and conduct after the shooting undermined self-defense; defendant lured them and acted to protect property, not life	Defendant maintained he acted in self-defense (shot at a shadow) and denied ambush intent; claimed some witnesses were accomplices and unreliable	Court found verdict was not against manifest weight: jurors were entitled to credit the state’s witnesses and conclude defendant was at fault and lacked a bona fide belief of imminent death/great harm

Key Cases Cited

State v. Goff, 82 Ohio St.3d 123 (Ohio 1998) (self-defense elements and review standards)
State v. Thomas, 77 Ohio St.3d 323 (Ohio 1997) (traditional self-defense formulation)
State v. Braden, 98 Ohio St.3d 354 (Ohio 2003) (prior calculation and design requires scheme/sufficient time to plan)
State v. Franklin, 97 Ohio St.3d 1 (Ohio 2002) (factors for evaluating prior calculation and design)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest weight standard)