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State v. Christon
2017 Ohio 9235
| Ohio Ct. App. | 2017
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Background

  • On June 16, 2015 Donald J. Christon III stabbed Tony Wilson multiple times during an argument in the family home; Wilson later died and the coroner ruled the death a homicide by multiple sharp-force trauma.
  • Christon was arrested at the scene while still holding a bloody butcher knife; officers and family witnesses described him as calm and compliant after the assault.
  • Christon pleaded not guilty and filed a written plea of not guilty by reason of insanity. He waived a jury and elected a bench trial.
  • The court ordered three court-ordered mental evaluations: Dr. Sherman (concluded Christon was competent and knew wrongfulness), Dr. Stinson (initial report equivocal; later concluded severe mental illness impacted perception), and Dr. Babula (concluded Christon, due to paranoid schizophrenia, did not know wrongfulness).
  • The trial court found Christon not guilty of one murder count but guilty under R.C. 2903.02(B) (murder as proximate result of committing or attempting to commit a violent offense). Sentenced to life with parole eligibility after 15 years.
  • The Sixth District Court of Appeals affirmed, holding the trial court did not abuse its discretion in crediting the State’s evidence and rejecting Christon’s insanity defense; the conviction was not against the manifest weight of the evidence.

Issues

Issue State's Argument Christon’s Argument Held
Whether Christon met his burden to prove not guilty by reason of insanity (R.C. standard: due to severe mental disease defendant did not know wrongfulness) Evidence (witness statements, dash-cam, Dr. Sherman) showed Christon understood and responded coherently after the offense; he admitted stabbing and acted calmly — he did not prove lack of knowledge of wrongfulness. Dr. Babula’s evaluation showed paranoid schizophrenia causing distorted perception such that Christon could not know the wrongfulness of his acts; Babula’s exam was more thorough and therefore more credible. Court upheld trial judge’s credibility determinations; Christon failed to prove insanity by a preponderance.
Whether the guilty finding was against the manifest weight of the evidence The record, including multiple admissions, eyewitness accounts, and expert opinion (Dr. Sherman), supports guilt beyond a reasonable doubt. The conflicting expert testimony (favoring Babula) meant the verdict was against the manifest weight. Court found no manifest miscarriage of justice; the verdict stands.

Key Cases Cited

  • Kokitka v. Ford Motor Co., 73 Ohio St.3d 89 (1995) (trier of fact decides witness credibility, including experts)
  • DeHass v. A.B. Chance Co., 10 Ohio St.2d 230 (1967) (trial court is sole judge of witness credibility)
  • State v. Thomas, 70 Ohio St.2d 79 (1982) (weight and credibility of insanity-defense evidence are for the trier of fact)
  • State v. Hancock, 108 Ohio St.3d 57 (2006) (defendant bears preponderance burden to prove insanity)
Read the full case

Case Details

Case Name: State v. Christon
Court Name: Ohio Court of Appeals
Date Published: Dec 22, 2017
Citation: 2017 Ohio 9235
Docket Number: L-16-1266
Court Abbreviation: Ohio Ct. App.