State v. Henderson
2021 Ohio 3943
| Ohio Ct. App. | 2021Background
- Defendant Christy Henderson was taken to Miami Valley Hospital after seizure-like activity and became combative; she was admitted to the advanced neurological unit.
- A patient-care technician, Mona Woods, was assigned as a sitter; tensions arose over requests (DoorDash, shower) and COVID restrictions.
- Woods testified Henderson slammed the door, charged her, then grabbed Woods by the hair, punched and kicked her; Woods suffered bruising and headaches; photos and multiple staff corroborated the attack.
- Henderson was charged with one count of misdemeanor assault (R.C. 2903.13), tried by jury, convicted, and sentenced to jail and probation.
- On appeal Henderson argued (1) insufficient evidence/manifest weight and (2) ineffective assistance because counsel declined a self-defense instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency and manifest weight of the evidence | Evidence (Woods’s testimony, staff corroboration, photos) proved elements beyond a reasonable doubt | Attack denied or excused by self-defense; conflicting witness accounts | Conviction affirmed: evidence sufficient; not against manifest weight |
| Ineffective assistance for declining self-defense instruction | Counsel’s strategy reasonable; self-defense unsupported so no prejudice | Counsel deficient for not requesting self-defense instruction | No ineffective assistance: self-defense would fail and was waived; no prejudice |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (Ohio 1991) (standard for sufficiency-of-the-evidence review)
- State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (Ohio 1997) (manifest-weight review formulation)
- State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (1st Dist. 1983) (used in Thompkins’ manifest-weight discussion)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
- State v. Bradley, 42 Ohio St.3d 136, 538 N.E.2d 373 (Ohio 1988) (prejudice prong: reasonable probability standard)
- State v. Bird, 81 Ohio St.3d 582, 692 N.E.2d 1013 (Ohio 1998) (deference to trial strategy in assessing counsel performance)
- State v. Poole, 33 Ohio St.2d 19, 294 N.E.2d 888 (Ohio 1973) (self-defense as an affirmative justification)
- State v. Bennett, 140 N.E.3d 1145 (2d Dist. 2019) (elements required to justify less-than-deadly force in self-defense)
- State v. Brock, 140 N.E.3d 1239 (2d Dist. 2019) (discussion of sufficiency review)