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