State v. Hargrave, 2012 Ohio 798

Hargrave killed his 75-year-old grandfather during a methamphetamine-fueled episode on March 21, 2010.
He lived with his grandparents and was unemployed at the time of the offenses.
Hargrave had been using meth for 2–3 months prior and ingested a large quantity that day.
During the incident in the garage, Hargrave stabbed his grandfather repeatedly (at least 28 wounds) and then punched his grandmother upon her entry.
He admitted killing his grandfather but claimed self-defense; his recollection of events was markedly blurred and inconsistent.
The jury convicted Hargrave of two counts of murder; sentence imposed 15 years to life and $4,000 restitution to the grandmother.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction for murder is against the manifest weight of the evidence	Hargrave argues self-defense was proven by preponderance.	State contends the evidence shows Hargrave was the aggressor and not entitled to self-defense.	Not against the manifest weight; substantial evidence supports murder verdict.
Whether restitution of $4,000 was improper given Hargrave's ability to pay	Hargrave argues the court abused its discretion by considering future prison income.	State argues the court properly considered present and future earnings and job history.	Restitution order affirmed; court properly assessed present and future ability to pay.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (weight of the evidence review governs manifest weight determinations)
State v. Goff, 128 Ohio St.3d 169 (2010) (self-defense elements include both objective reasonableness and subjective belief)
State v. Hendrickson, 4th Dist. No. 08CA12 (2009) (self-defense force must be reasonably necessary and not excessive)
State v. Cassano, 96 Ohio St.3d 94 (2002) (cumulative elements of self-defense and standard of review for acquittal)
State v. Jackson, 22 Ohio St.3d 281 (1986) (principles on self-defense and retreat duties)
State v. Thomas, 77 Ohio St.3d 323 (1997) (establishes the mixed subjective-objective standard for self-defense)