State v. Chandler, 2017 Ohio 8573

Background

Defendant Roosevelt Chandler lived across from the victim in an apartment complex; an earlier verbal altercation occurred between the victim and Mrs. Chandler at her open window.
Several minutes later Chandler, carrying a loaded revolver, confronted the victim in the parking lot and fired multiple shots, reloading at least once.
The victim was shot; a seven-year-old bystander was grazed by a bullet and treated for a bullet-like wound.
Chandler testified and claimed he shot in self-defense because he believed the victim reached for a weapon; the jury was instructed on self-defense and convicted Chandler of two counts of felonious assault with separate three-year firearm specifications.
Trial court refused requests to instruct on defense-of-another and the Castle Doctrine (R.C. 2901.05(B)); trial court also limited admission of prior-act evidence to impeachment and allowed intrinsic impeachment through cross-examination.
Chandler appealed, arguing errors in jury instructions, Evid.R. 404(B) admission, sufficiency/manifest weight of the evidence, and excessiveness of sentence; the court affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court erred by refusing instructions on defense of another and Castle Doctrine	State: no instruction required because evidence did not support statutory presumption or defense-of-another elements	Chandler: he reasonably believed Mrs. Chandler remained in imminent danger and claims the statutory presumption (Castle Doctrine) applies	Court: refusal proper — no evidence Mrs. Chandler was in danger when shooting occurred and presumption inapplicable (victim was a lawful resident)
Admission of prior-act evidence under Evid.R. 404(B)	State: limited use for impeachment and admissible on cross-exam if defendant testified inconsistently	Chandler: trial court improperly allowed prior weapon-related incidents as substantive propensity evidence	Court: no reversible error — trial court precluded substantive 404(B) use; challenged statements were intrinsic impeachment elicited during Chandler's testimony and not pursued as extrinsic evidence
Sufficiency and manifest weight of the evidence for felonious assault convictions	State: evidence (victim testimony, paramedic, timing, defendant's admission he shot) supports convictions for (A)(2) felonious assault and linking child’s wound to defendant’s shooting	Chandler: child’s wound could have another cause; his testimony supports self-defense	Court: evidence legally sufficient and not against the manifest weight — jury credited prosecution witnesses over defendant
Sentence excessiveness challenge	State: eight-year aggregate sentence is statutory minimum given consecutive firearm specifications and underlying terms	Chandler: challenges sentence as excessive and contends labeling of specifications at trial was error	Court: declined — eight years is statutory minimum; labeling at trial not reversible and defendant provided no authoritative support

Key Cases Cited

State v. Fulmer, 117 Ohio St.3d 319 (Ohio 2008) (trial court discretion to instruct jury only when evidence supports instruction)
State v. Fields, 13 Ohio App.3d 433 (8th Dist. 1984) (jury instructions reviewed as a whole for prejudicial error)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for sufficiency review: viewing evidence in light most favorable to prosecution)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest-weight standard and when reversal is warranted)
State v. Drummond, 111 Ohio St.3d 14 (Ohio 2006) (distinguishing weight-of-evidence review from sufficiency review)
State v. Antill, 176 Ohio St. 61 (Ohio 1964) (jury may accept or reject any witness testimony and weigh inconsistencies)
State v. Goff, 128 Ohio St.3d 169 (Ohio 2010) (elements required for defense-of-another/self-defense instructions)
State v. Jackson, 22 Ohio St.3d 281 (Ohio 1986) (defense-of-another parallels self-defense; defendant stands in victim's shoes)
State v. Hamilton, 77 Ohio App.3d 293 (12th Dist. 1991) (intrinsic impeachment via cross-examination under Evid.R. 608(B))