State v. Daley, 2020 Ohio 4390

On November 21, 2017, Shane M. Daley (aka “Fredo”) and co‑defendant Mackenzie Litteral went to Christopher Pfaff’s apartment to retrieve a cellphone; an altercation ensued and Pfaff was fatally shot. Several eyewitnesses (apartment guests and the driver who waited outside) testified about the events.
Eyewitnesses largely described Daley grabbing Pfaff, pointing a handgun at occupants, and firing; others described Pfaff and an occupant also drawing a weapon. Police recovered spent cartridge cases, a .38 bullet, and other evidence; parties stipulated to the coroner’s cause of death (single gunshot) and certain firearms/forensic facts.
Daley was indicted on counts including murder (felony‑murder), kidnapping, having a weapon while under disability, and firearm specifications; the trial court granted acquittal on aggravated burglary.
The jury convicted Daley of murder (felony‑murder), kidnapping, having a weapon while under disability, and most firearm specifications; he was sentenced to an aggregate 24 years to life.
On appeal Daley challenged (framed as sufficiency/manifest‑weight) the murder and kidnapping convictions and argued eyewitnesses were untruthful and that he acted in self‑defense. The court treated the claim as a manifest‑weight challenge and affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Daley)	Held
Whether convictions for murder (felony‑murder) and kidnapping were supported by sufficient evidence / not against manifest weight	Eyewitness testimony was consistent that Daley grabbed Pfaff, brandished and fired a gun, and fled; corroborating conduct (preventing 911 call, disposing of gun, changing appearance) shows consciousness of guilt	Witnesses lied/obstructed (hid evidence, misremembered); Daley acted in self‑defense because Pfaff and others were armed and shot Litteral first	Affirmed. The jury reasonably credited eyewitnesses; record did not show the jury lost its way.
Whether prosecution disproved self‑defense under amended R.C. 2901.05	By proving Daley was at fault in creating the affray and adducing conduct inconsistent with self‑defense, the State disproved at least one self‑defense element beyond a reasonable doubt	Daley says he was not the aggressor, acted in response to Pfaff firing, and only fired to escape imminent deadly force	Held for State: evidence supported finding Daley was at fault in creating the confrontation and thus undermined his self‑defense claim.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest‑weight standards)
State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency standard for criminal convictions)
State v. Yarbrough, 95 Ohio St.3d 227 (2002) (sufficiency review does not permit reassessment of witness credibility)
State v. Nolan, 141 Ohio St.3d 454 (2014) (felony‑murder requires intent to commit the predicate felony but not intent to kill)
State v. Miller, 96 Ohio St.3d 384 (2002) (discussion of mens rea under felony‑murder)
State v. Fry, 125 Ohio St.3d 163 (2010) (further discussion of felony‑murder intent issues)
State v. Robbins, 58 Ohio St.2d 74 (1979) (self‑defense elements and burden considerations)
Seasons Coal Co., Inc. v. Cleveland, 10 Ohio St.3d 77 (1984) (deference to trier of fact on witness demeanor and credibility)
State v. Martin, 20 Ohio App.3d 172 (1983) (manifest‑weight reversal is reserved for exceptional cases)