State v. Griffin, 2018 Ohio 3119

Defendant Walter Griffin returned to a motel room where he lived and confronted four people, including Kenneth Sutton and Melanie, after noticing money missing from his car.
Griffin observed drug use in the room and accused Sutton and Melanie of theft; he told occupants they could not leave and blocked egress.
Griffin grabbed a three-foot ax handle kept in the room and struck Sutton once in the head and twice in the leg as Sutton was leaving in a cab.
Police interviewed both men; Griffin claimed self-defense, asserting he feared Sutton based on Sutton’s eyes, movement, and a purported kick attempt.
After a bench trial in Hamilton Municipal Court, Griffin was convicted of assault (R.C. 2903.13(A)); he appealed arguing the conviction was against the manifest weight of the evidence.
The trial court found Griffin acted out of anger, was the only person armed, and did not credibly show he feared for his safety; this court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Griffin’s conviction was against the manifest weight of the evidence	State: evidence supports assault conviction; trial court reasonably found Griffin not credible on self-defense	Griffin: conviction against manifest weight because he acted in self-defense—he feared imminent harm	Affirmed: not against manifest weight; trial court credited State and found no reasonable fear or justification
Whether Griffin established self-defense to negate knowing causing of physical harm	State: Griffin failed to prove he was not at fault and lacked objectively reasonable belief of imminent harm	Griffin: he reasonably and honestly believed Sutton posed an imminent threat (movement, eyes, alleged kick)	Held: self-defense not established; force was not reasonably necessary and Griffin initiated and escalated the confrontation

State v. Williford, 49 Ohio St.3d 247 (Ohio 1990) (defendant privileged to use only force reasonably necessary to repel an attack)