State v. Kurtz, 2018 Ohio 3942

On June 26, 2015, Kyle Z. Kurtz went to Jeanette Hampton's home to buy marijuana; an argument with Hampton's boyfriend, Brandon Brown, escalated outside her side door.
Witnesses saw both men armed; Brown placed his gun on the hood of a car and raised his hands before Kurtz shot Brown multiple times; Brown died from multiple gunshot wounds.
Kurtz was arrested nearby; police recovered two 9mm pistols from Kurtz's vehicle and shell casings at the scene matching Kurtz's gun.
A Franklin County grand jury indicted Kurtz on aggravated robbery, kidnapping, aggravated murder (including a prior calculation/design count of aggravated murder), murder counts, and tampering with evidence; most counts included firearm specifications.
Kurtz admitted shooting Brown but claimed self-defense, asserting Brown had pointed a gun at him and then reached for it; the jury rejected self-defense and convicted on all counts except one aggravated-murder theory and the tampering count.
The trial court sentenced Kurtz to 20 years to life plus consecutive firearm-specification terms; Kurtz appealed, challenging sufficiency and manifest weight of the evidence (claiming self-defense).

Issue	State's Argument	Kurtz's Argument	Held
Whether convictions (aggravated murder, murder, kidnapping, aggravated robbery) were supported by sufficient evidence and not against the manifest weight of the evidence	Evidence (eyewitness testimony, physical evidence, bullets trajectories, shell casings, possession of Brown's gun after shooting) supports the convictions and undermines self-defense	Kurtz conceded shooting but argued he acted in self-defense because Brown pointed a gun at him, placed it on the hood, then reached for it; he denied provoking the confrontation	The court affirmed: evidence was sufficient and the jury did not lose its way; Kurtz failed to prove self-defense by a preponderance (disputed credibility, shots to victim's back, continued firing when victim turned away)

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency of the evidence from manifest-weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency: viewing evidence in light most favorable to the prosecution)
State v. Robinson, 124 Ohio St.3d 76 (2009) (reiterating the Jenks standard for sufficiency)
State v. Robbins, 58 Ohio St.2d 74 (1979) (elements a defendant must prove to establish deadly-force self-defense)
Jackson v. State, 22 Ohio St.3d 281 (1986) (use-of-force proportionality and cumulative elements of self-defense)
Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (1984) (deference to factfinder on witness credibility)
State v. Yarbrough, 95 Ohio St.3d 227 (2002) (appellate courts do not reassess witness credibility in sufficiency review)