State v. Chisolm, 2023 Ohio 604

In the early morning of March 20, 2021, D.J. was found dead on the shoulder of I‑77 with a contact gunshot wound to the right side of her neck; the medical examiner ruled the manner of death a homicide.
Chisolm had purchased a 9mm Masada pistol weeks earlier; the gun used to shoot D.J. was his firearm.
Videos placed the victim’s Mazda on city streets shortly before the body was found; surveillance showed a blue minivan following the Mazda.
Chisolm was the only other person known to be in the car; he abandoned D.J.’s body and later abandoned the Mazda, lied to family and police about being shot at, and gave inconsistent accounts of the gun’s disposition.
Investigators recovered D.J.’s phone at an address where Chisolm stayed; the phone had been factory reset. No shell casings or firearm were recovered at the scene or in the Mazda.
A jury convicted Chisolm of two counts of murder (R.C. 2903.02(A) and (B)), two counts of felonious assault (R.C. 2903.11(A)(1) and (A)(2)), and abuse of a corpse; most counts merged for sentencing and the court imposed an aggregate sentence of life with parole eligibility after 19 years.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Chisolm)	Held
Sufficiency of evidence to prove mens rea for murder and felonious assault (Counts 2–5)	Circumstantial evidence—Chisolm’s gun was used, it was pressed to victim’s neck, he was sole person in car, he left the scene, lied repeatedly, phone reset, and surveillance—supports intent/knowledge.	Shooting was accidental/self‑inflicted; state failed to prove specific intent or that Chisolm knowingly caused harm.	Evidence was sufficient to prove purpose/knowledge; convictions for murder and felonious assault affirmed.
Manifest‑weight challenge to convictions (Counts 2–5)	Jury reasonably credited the state’s circumstantial evidence and the medical examiner’s homicide determination.	Dr. Dolinak said wound could be consistent with self‑inflicted injury; verdict was against the weight of the evidence.	Jury verdicts were not against the manifest weight; convictions stand.

State v. Jenks, 61 Ohio St.3d 259 (sufficiency standard for criminal convictions)
State v. Thompkins, 78 Ohio St.3d 380 (manifest‑weight review; appellate court as thirteenth juror standard)
State v. Franklin, 62 Ohio St.3d 118 (circumstantial evidence may sustain conviction)
State v. Nicely, 39 Ohio St.3d 147 (circumstantial evidence equivalence to direct evidence)
Garner v. State, 74 Ohio St.3d 49 (presumption that actors intend natural and probable consequences)
Tibbs v. Florida, 457 U.S. 31 (appellate review of weight of the evidence principles)