State v. Lathan, 2024 Ohio 2514

Darryl Lathan, II was convicted of murder, felonious assault (with firearm specifications), and failure to comply with a police order after a fatal 2021 nightclub parking lot shooting in Toledo, Ohio.
Lathan claimed self-defense, alleging that the victim, A.R., had previously threatened him, was armed and masked during the incident, and that Lathan only shot A.R. after perceiving an imminent threat.
The State presented evidence including multiple eyewitness testimonies and video footage, arguing that A.R. was shot in the back and that Lathan fled the scene and led police on a high-speed chase, undermining his self-defense claim.
Lathan sought to introduce a rap video, posted by A.R. months before the shooting, allegedly containing threats against him, but the trial court excluded the video due to untimely disclosure in violation of Ohio discovery rules.
After conviction, Lathan moved for a new trial, claiming juror misconduct due to an undisclosed connection between a juror and defense counsel's wife, but the trial court denied the motion.
Lathan appealed, raising issues about exclusion of evidence, the weight of the evidence on self-defense, and the denial of a new trial based on possible juror bias.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of late-disclosed rap video	Video was key to self-defense showing credible fear; should be admitted; exclusion violated Sixth Amendment right.	Exclusion within court's discretion due to late disclosure; video content testified to by Lathan so no prejudice.	Exclusion proper; no abuse of discretion under Crim.R. 16/12.2 as Lathan could testify to contents; no violation found.
Manifest weight of the evidence (self-defense)	Evidence clearly favored that Lathan acted in self-defense; jury lost its way in rejecting his claim.	State’s witnesses and video credible; A.R. shot in the back and Lathan fled, supporting guilt; jury decision reasonable.	Verdict upheld; jury did not clearly lose its way; conviction not against manifest weight of evidence.
Denial of new trial due to juror connection	Juror’s failure to disclose connection to defense counsel’s wife and rejected advance created bias; warranted new trial.	Juror was not asked about such connections during voir dire; defense knew before verdict and did not notify court; no proof of prejudice or misconduct.	Denial proper; no evidence of juror misconduct or dishonesty; issue could have been raised before verdict.

State v. Conway, 108 Ohio St.3d 214 (standard for reviewing evidentiary decisions—abuse of discretion)
State v. Issa, 93 Ohio St.3d 49 (review of trial court evidentiary rulings)
State v. Thompkins, 78 Ohio St.3d 380 (manifest weight standard for appellate review)
State v. Papadelis, 32 Ohio St.3d 1 (trial court must impose least severe sanction for discovery violations)
State v. Barnes, 94 Ohio St.3d 21 (elements of self-defense in Ohio)
State v. Howard, 56 Ohio St.2d 328 (intent of criminal discovery rules is fair trial, not gamesmanship)
State v. Messenger, 161 Ohio St.3d 53 (self-defense as an affirmative defense; State's burden to disprove)
State v. Petro, 148 Ohio St. 505 (standards for new trial based on newly discovered evidence)