State v. Hill, 2020 Ohio 1237

Appellant Jamaine Hill was indicted after a Toledo SWAT no‑knock warrant execution; he fired a handgun as officers breached his front door, striking one officer (J.P.) who required jaw surgery.
Seven counts of felonious assault (each with firearm specifications) were brought — one for six SWAT officers and one for J.P. — plus one count of possession of a weapon while under disability.
At trial Hill testified he awoke confused by pain medication, believed an intruder was breaking in, and fired before realizing officers were entering; officers and forensic reconstruction contradicted parts of his account.
The jury convicted Hill on all counts; trial court sentenced him to an aggregate 47 years and imposed costs, including court‑appointed counsel fees and confinement costs.
On appeal Hill raised (1) denial of Crim.R. 29 motion as to Counts 3, 4, and 7 (sufficiency), (2) verdict against the manifest weight of the evidence, and (3) improper imposition of non‑mandatory costs without finding ability to pay.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hill)	Held
Sufficiency (Crim.R.29) for Counts 3,4,7 (felonious assault)	Evidence showed Hill fired into doorway, officers were in the area and at risk; intent/knowing element met	Hill lacked knowledge that victims were police and lacked awareness of how many officers were present, so state didn’t prove knowing attempt	Affirmed — sufficient evidence; state need not prove Hill knew victims were officers and need not prove he knew the number of potential victims
Manifest weight of the evidence	Physical evidence, video, officer testimony, and reconstruction support convictions; Hill’s self‑defense claim contradicted by his testimony and reconstruction	Verdict is against weight because Hill acted in fear/confusion from medication and believed he was repelling an intruder	Affirmed — no manifest miscarriage of justice; credibility and weight for jury
Imposition of costs (appointed counsel fees, confinement costs)	Costs were properly imposed	Trial court failed to determine Hill’s present/future ability to pay non‑mandatory costs	Partial reversal — mandatory prosecution costs affirmed; appointed counsel and confinement costs vacated for lack of ability‑to‑pay finding

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (standards for custodial interrogation and admissibility of statements)
State v. Smith, 80 Ohio St.3d 89 (Ohio 1997) (sufficiency review standard: view evidence in light most favorable to prosecution)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest‑weight standard; appellate court as thirteenth juror)
State v. Were, 118 Ohio St.3d 448 (Ohio 2008) (appellate deference and evaluation of witness credibility)
State v. Dean, 146 Ohio St.3d 106 (Ohio 2015) (transferred intent can satisfy mens rea for felonious assault)
State v. Martin, 20 Ohio App.3d 172 (Ohio Ct. App. 1983) (trial court should exercise restraint when granting new trial on weight grounds)