State v. Franklin, 2020 Ohio 532

Malcolm Franklin went to D.J.’s Nite Spot and fired multiple shots from outside a tall wooden fence into an enclosed patio; three people were hit, one (Julian Johnson) died at the scene.
Police recovered 11 spent shell casings outside the fence; Franklin’s firearm (forensic match to casings) was later recovered after he discarded it; a handgun was found unloaded under the victim.
Witnesses (Natasha, Ashley, Jeff) testified they did not see the victim with or fire a weapon; only Franklin claimed Julian had a gun and that he fired after hearing what he thought was gunfire.
Franklin initially denied being at the bar, gave multiple changing statements, and eventually admitted firing his weapon; he also approached the bar wearing dark clothing and a partially obscured face, waited outside the fence, and shot into the patio.
Indicted for murder (R.C. 2903.02(B)), multiple felonious-assault counts with firearm specifications, and tampering with evidence; jury convicted on all counts, merged allied offenses, and trial court sentenced Franklin to 40 years to life.
Franklin appealed only the murder conviction, arguing his actions were justified by self-defense; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Franklin’s murder conviction was against the manifest weight of the evidence because he acted in self-defense	State: evidence disproved self-defense—witnesses saw no gun in victim’s hands, casings matched Franklin’s gun, Franklin concealed himself, discarded the weapon, and gave inconsistent statements	Franklin: he was not at fault, believed he and a friend were in imminent danger after hearing what he thought was gunfire, and used deadly force to defend himself	Court: Affirmed conviction; jury’s credibility finding stands. Franklin failed to prove self-defense—he created the affray, no bona fide reasonable belief of imminent deadly harm supported, and he could have avoided the danger

State v. Palmer, 80 Ohio St.3d 543 (1997) (holds self-defense is an affirmative defense and places the burden of proof on the accused)