State v. Davidson-Dixon, 170 N.E.3d 557

Defendant Denayne Davidson-Dixon was indicted for felonious assault and domestic violence after his wife, Shianne Adams, sustained serious facial fractures; defendant admitted causing the injuries but claimed self-defense.
Facts in dispute: prior incidents at a wedding, Adams allegedly threw a key‑fob, unplugged Wi‑Fi, and (per defendant) later punched him and came at him with scissors; defendant said he punched once in reaction.
EMS and hospital records confirmed serious physical harm; defendant introduced photos and texts suggesting Adams admitted a punch and threat with scissors.
At trial the court refused defendant’s requested jury instruction on nondeadly self‑defense but instructed on aggravated assault as an inferior offense; the jury convicted on aggravated assault and domestic violence and the court sentenced defendant to 18 months.
On appeal defendant argued the trial court abused its discretion by refusing the self‑defense instruction; the court of appeals reversed and remanded for a new trial, concluding the instruction should have been given.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by refusing to instruct the jury on nondeadly self‑defense	State: defendant provoked or created the situation by going into the bedroom and thus was not entitled to self‑defense instruction	Davidson‑Dixon: presented evidence (photos, texts, testimony) that Adams initiated attack, threatened him with scissors, and he acted in reasonable, nondeadly self‑defense	Reversed — court held defendant produced sufficient evidence, when viewed in his favor, to raise a jury question on nondeadly self‑defense and the instruction should have been given
Whether ineffective assistance of counsel requires relief	State: not reached at this stage	Defendant: argued trial counsel ineffective	Court: rendered ineffective assistance claim moot because reversal was required on instructional error

State v. Wolons, 44 Ohio St.3d 64 (1989) (standard for appellate review of refusal to give requested jury instruction)
State v. Melchior, 56 Ohio St.2d 15 (1978) (standard for when an affirmative‑defense instruction must be given)
State v. Comen, 50 Ohio St.3d 206 (1990) (trial courts must give instructions necessary and relevant for jury to weigh evidence)
Goldfuss v. Davidson, 79 Ohio St.3d 116 (1997) (criteria for giving jury instructions)
State v. Robinson, 47 Ohio St.2d 103 (1976) (court should view evidence in favor of defendant when deciding whether to give an affirmative‑defense instruction; credibility is for the jury)
State v. Triplett, 192 Ohio App.3d 600 (2011) (single punch generally constitutes nondeadly force)
State v. Morton, 147 Ohio App.3d 43 (2001) (prosecution must disprove elements of self‑defense beyond a reasonable doubt once defendant produces sufficient evidence)
Cleveland v. Welms, 169 Ohio App.3d 600 (2006) (no duty to retreat when nondeadly force is used)