State v. Huguley, 2017 Ohio 8300

Background

Michael Huguley and Jasmine Williams were in a relationship, lived together, and shared a child; on June 23, 2015 Williams was fatally stabbed in their apartment.
Huguley and a roommate/witness (D.D.) gave conflicting accounts: Huguley claimed Williams stabbed him first and he acted in self-defense; D.D. testified Huguley pulled a knife and stabbed Williams, then himself, and fled.
Huguley was arrested five weeks later and indicted for aggravated murder, murder, felonious assault, and domestic violence; a jury acquitted aggravated murder but convicted him of murder and related counts; merged sentences produced 15 years-to-life for murder.
Pretrial and trial disputes included: (1) a motion to suppress Huguley’s consent to DNA collection after he referenced a lawyer, (2) a discovery violation when the State belatedly produced phone data, and (3) alleged juror misconduct by the jury foreperson researching his role.
At trial the defense argued self-defense under Ohio law (Robbins elements); the State emphasized evidence undermining Huguley’s credibility, physical evidence, and that Huguley had disarmed Williams before stabbing her.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Huguley)	Held
1. Motion to suppress: did Huguley invoke right to counsel when he mentioned a lawyer re: DNA consent?	Police: Huguley’s question was an equivocal request; consent was voluntary; no invocation, so statements/consent admissible.	Huguley: He asked for a lawyer and questioning/collection should have stopped; suppression required.	Court: Denied suppression — remark was equivocal, not an unambiguous invocation of right to counsel.
2. Discovery violation: did the belated disclosure of extracted phone data require mistrial?	State: disclosure was inadvertent, provided immediately; continuance and reordering of witnesses cured any prejudice.	Huguley: Late production could contain exculpatory evidence; mistrial warranted.	Court: Denied mistrial — violation was not willful; continuance was least drastic adequate remedy; no shown prejudice.
3. Juror misconduct: should foreperson have been removed or mistrial declared after he researched duties?	State: Foreperson’s answers assuaged concerns; parties (including defense counsel) chose to keep juror.	Huguley: Foreperson’s outside research compromised impartiality; removal or mistrial required despite counsel’s decision.	Court: Waiver controls — defense affirmatively waived objection as tactical decision; no appellate relief.
4. Manifest weight/self-defense: Was the conviction against the manifest weight because Huguley proved self-defense by preponderance?	State: Evidence supports jury’s disbelief of self-defense; Huguley disarmed Williams and force thereafter was excessive/unreasonable.	Huguley: He was initial victim, feared imminent death/great bodily harm, so his use of deadly force was justified.	Court: Affirmed conviction — after weighing credibility and evidence, jury did not lose its way; Huguley failed to prove all self-defense elements.

Key Cases Cited

State v. Burnside, 100 Ohio St.3d 152 (de novo review of legal conclusions in suppression rulings)
Davis v. United States, 512 U.S. 452 (equivocal references to counsel do not require cessation of questioning)
State v. Henness, 79 Ohio St.3d 53 (police must cease questioning after clear request for counsel)
State v. Darmond, 135 Ohio St.3d 343 (discovery-sanction analysis and trial-court discretion)
Lakewood v. Papadelis, 32 Ohio St.3d 1 (trial court must impose least severe sanction for discovery violations)
State v. Robbins, 58 Ohio St.2d 74 (elements required to establish self-defense when deadly force used)
State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight-of-the-evidence standard)
State v. Jackson, 22 Ohio St.3d 281 (self-defense burden and jury’s role in credibility)
State v. Otten, 33 Ohio App.3d 339 (appellate review as "thirteenth juror" when examining manifest weight)