State v. Degahson, 2022 Ohio 2972

Defendant Ulonda Degahson and victim Dewand Moore had a deteriorating sexual relationship; Degahson alleged Moore was possessive and abusive.
In the early morning of Aug. 21, 2019, an altercation occurred at Degahson’s home/driveway; Degahson retrieved a gun, approached Moore, and shot him multiple times; Moore died from internal hemorrhaging from multiple gunshot wounds.
Crime-scene evidence included multiple shell casings and bullets recovered across the street and on adjacent properties; autopsy showed multiple entry and exit wounds.
Degahson admitted shooting Moore; she claimed self-defense and sought a jury instruction reflecting the 2021 S.B. 175 “stand your ground” amendment (no duty to retreat).
The trial court denied the S.B. 175 instruction as inapplicable retroactively and instructed under the pre-amendment duty-to-retreat law; the jury convicted Degahson of felony murder and felonious assault with firearm specifications.
The court merged counts, the State elected felony murder, and Degahson was sentenced to 18 years to life; she appeals arguing erroneous jury instruction and manifest-weight error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by refusing to give a S.B. 175 “no duty to retreat” (stand your ground) jury instruction	S.B. 175 is substantive and not intended to apply retroactively; R.C. 1.58 requires applying the former law to pending prosecutions	S.B. 175 was effective before trial and therefore the updated self-defense instruction eliminating duty to retreat should be given	Affirmed. The amended statute is substantive, not retroactive; R.C. 1.58 requires application of the pre‑amendment duty‑to‑retreat law to pending cases.
Whether the conviction was against the manifest weight of the evidence	The jury’s verdict should be upheld because evidence (including Degahson’s inconsistent statements and lack of observed injuries) supports rejection of self‑defense	Degahson claims her shooting was justified self‑defense based on prior abuse and Moore’s alleged lunge	Affirmed. Credibility was for the jury; reasonable inferences support the verdict and no miscarriage of justice occurred.

Hyle v. Porter, 882 N.E.2d 899 (Ohio 2008) (statutes presumed prospective; retroactive application requires clear legislative intent)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (standard for manifest‑weight review)
State v. Martin, 20 Ohio App.3d 172 (Ohio Ct. App. 1983) (framework for weighing evidence and credibility in manifest‑weight analysis)
Smiley v. State, 966 So.2d 330 (Fla. 2007) (stand‑your‑ground amendment is substantive and not retroactive)
People v. Conyer, 762 N.W.2d 198 (Mich. Ct. App. 2008) (duty‑to‑retreat amendment created substantive right; not retroactive)
Commonwealth v. Stone, 291 S.W.3d 696 (Ky. 2009) (no‑duty‑to‑retreat change was substantive and lacked retroactive application)
Blalock v. State, 452 P.3d 675 (Alaska App. 2019) (stand‑your‑ground change is substantive)
State v. Mahler, 157 So.3d 626 (La. Ct. App. 2013) (stand‑your‑ground amendment substantive and prospective only)