State v. Csehi, 2024 Ohio 779

Nicholas T. Csehi was indicted for Aggravated Murder and Murder, with a firearm specification, after shooting Randall Cohen following a physical altercation at a family home in Ashtabula County.
The altercation began with a verbal dispute and escalated into physical fights both inside and outside the house; Csehi ultimately shot Cohen outside by his vehicle.
At trial, Csehi claimed self-defense, testifying that Cohen choked him to the point of near unconsciousness and that he shot Cohen to protect himself.
The jury acquitted Csehi of Aggravated Murder but convicted him of Murder with the firearm specification. The trial court sentenced him to 15 years-to-life plus three years for the firearm specification to be served consecutively.
On appeal, Csehi argued that the conviction was against the manifest weight of the evidence because the State failed to disprove self-defense, and also challenged the State’s use of a peremptory strike (Batson challenge) as racially discriminatory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight of the Evidence (Self-defense)	State disproved self-defense; Csehi did not honestly or reasonably believe deadly force was necessary	Csehi acted in self-defense; State failed to disprove it beyond reasonable doubt	Conviction not against manifest weight; jury findings on credibility upheld
Batson Challenge	Strike was race-neutral; juror had non-racial attendance challenges	Strike was racially motivated and juror was only non-white member	No prima facie evidence of discrimination; peremptory challenge upheld

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (appellate courts as 'thirteenth juror' in weight of evidence review)
State v. Messenger, 171 Ohio St.3d 227 (Ohio 2022) (burdens in self-defense cases under Ohio law)
Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibited race-based peremptory juror strikes)
State v. Johnson, 88 Ohio St.3d 96 (Ohio 2000) (Batson challenge procedural framework and appellate review standard)