State v. McBride, 2020 Ohio 559

On June 13, 2018, Larry McBride and several neighbors were on the common front porch of a multi-unit apartment complex when an altercation occurred with neighbor Darrell "Raven" Deubel.
Earlier Deubel wore a knife in a sheath on his belt; tenants expressed concern but witnesses said Deubel never drew the knife during the incident.
McBride left the porch, put on a prosthetic leg, returned with a walker and a large knife, and after a shove from Deubel stabbed him in the neck; Deubel later died from massive blood loss caused by an 8" wound.
Witnesses saw McBride stab Deubel; McBride made statements to officers (including that Deubel ran into the knife) and led officers to a blood-covered knife.
McBride was indicted for Murder (R.C. §2903.02(B)) and Felonious Assault (R.C. §2903.11); a jury convicted on both counts and the court imposed a sentence of 15 years-to-life.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the convictions for murder and felonious assault were supported by sufficient evidence	State: Viewing evidence in light most favorable to prosecution, evidence proved all elements beyond a reasonable doubt	McBride: Claimed self-defense and that victim ran into the knife; contends convictions against sufficiency/weight	Court: Affirmed convictions; sufficiency standard satisfied and self-defense is affirmative (not a sufficiency challenge); manifest-weight review rejects McBride's self-defense claim
Whether McBride proved self-defense by a preponderance	State: Evidence showed McBride armed himself, returned to confront victim, and inflicted a deep fatal wound; witnesses heard no threats from victim	McBride: Argued he was not at fault, feared imminent harm, and that victim caused the injury by running into the knife	Court: Rejected self-defense on manifest-weight review—jury credited prosecution; McBride failed to meet elements (not faultless, not shown imminent threat, no duty-to-retreat analysis changed result)

State v. Jenks, 61 Ohio St.3d 259 (1991) (sets Ohio standard for sufficiency review following Jackson)
Jackson v. Virginia, 443 U.S. 307 (1979) (constitutional sufficiency standard: any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Martin, 20 Ohio App.3d 172 (1983) (standard for manifest-weight review and when to grant new trial)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (discusses distinction between sufficiency and manifest-weight review)
State v. Barnes, 94 Ohio St.3d 21 (2002) (elements required to establish self-defense)
State v. Hancock, 108 Ohio St.3d 57 (2006) (affirmative defenses not subject to sufficiency review)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight of evidence are jury province)
Antill v. State, 176 Ohio St. 61 (1964) (jury may accept only portions of witness testimony)