2014 Ohio 3466
Ohio Ct. App.2014Background
- On Sept. 22, 2013, after being ejected earlier, Roussiel Medlock approached patrons in the parking lot of Nathan’s Patio Bar and Grill and got into an argument with Deborah Anderson and her sister Jackie Austin.
- Jackie, wearing high heels, allegedly hit Medlock with a shoe during an earlier exchange; later Medlock warned Jackie “I’ll knock you out” and then punched her, loosening teeth and splitting her lip.
- Deborah retrieved a crowbar and confronted Medlock; he made additional threats toward her. A bouncer observed Medlock celebrating after the strike.
- Deputy Craig Kennedy arrested Medlock; Medlock told the deputy Jackie had charged him but also said he ‘‘taught her a lesson.’’ Medlock appeared intoxicated.
- Medlock was charged with one count of assault (R.C. 2903.13(A)), tried by jury, given a self-defense instruction, convicted, and sentenced to 180 days in jail. He appealed, arguing the conviction was unsupported by sufficient evidence and against the manifest weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence was sufficient and the verdict against the manifest weight of the evidence given Medlock's claim of self-defense | State: Evidence (victim injury, threats, celebratory conduct, admissions) supports conviction; self-defense not proved | Medlock: Claimed Jackie charged him and he acted in self-defense | Court: Evidence sufficient; verdict not against manifest weight; self-defense rejected because defendant admitted motive was to "teach her a lesson" and circumstances did not support reasonable belief in necessity of force |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (1997) (discusses manifest-weight review and appellate role as thirteenth juror)
- State v. Jenks, 61 Ohio St.3d 259 (1991) (defines sufficiency-of-evidence standard for criminal convictions)
- State v. Martin, 20 Ohio App.3d 172 (1983) (quoted standard for manifest-weight analysis)
- State v. Caldwell, 79 Ohio App.3d 667 (1992) (places burden of proving self-defense by a preponderance when raised by defendant)