State v. Murray, 2016 Ohio 7501

On July 23, 2015, gunfire occurred near Nicole Nelson’s home; shell casings and bullet damage were found at the scene and inside the house.
Darion Murray arrived at a hospital that night with a gunshot wound; his car (a maroon Chevy Impala) showed multiple fresh bullet strikes and had two .380 casings on the front passenger seat.
Crime lab testing connected the .380 casings found in the road in front of Nelson’s home with the .380 casings recovered from Murray’s car; other recovered fragments were .40 caliber.
Murray gave varying statements: initially saying someone put a hand/baggie into his car and later stating he was alone, had no gun, and no shots were fired from his car.
Murray was indicted on improperly discharging at/into a habitation (R.C. 2923.161) and improperly handling firearms in a motor vehicle (R.C. 2923.16); the jury acquitted on the habitation count and convicted on the motor vehicle count.
The trial court sentenced Murray to 18 months; Murray appealed, arguing insufficiency and manifest-weight error as to the motor-vehicle firearm conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to support conviction for improperly handling firearms in a motor vehicle (knowingly discharging a firearm in/on a motor vehicle)	State: physical evidence (matching .380 casings in road and Murray’s car, bullet in Murray’s car, bullet holes on Murray’s vehicle, Murray’s wound) permits a rational jury to find Murray fired from his vehicle	Murray: he lacked a gun and did not fire; alternate theory that shots came from the house/crowd; inconsistent statements create reasonable doubt	Court: Evidence—direct and circumstantial—was sufficient; conviction affirmed
Whether conviction was against the manifest weight of the evidence	State: jury reasonably credited physical and forensic evidence over Murray’s statements	Murray: jury should have rejected State’s theory given inconsistencies and alternative explanations	Court: Not an exceptional case; jury did not lose its way; conviction not against manifest weight

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
McDaniel v. Brown, 558 U.S. 120 (reaffirming Jackson standard)
State v. Fry, 125 Ohio St.3d 163, 926 N.E.2d 1239 (Ohio precedent cited re: sufficiency review)
State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (weight of the evidence standard)
State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (circumstantial evidence has same probative value as direct evidence)
State v. Lott, 51 Ohio St.3d 160, 555 N.E.2d 293 (permissible inferences from facts)
Seasons Coal Co., Inc. v. Cleveland, 10 Ohio St.3d 77, 461 N.E.2d 1273 (deference to verdict; reasonable intendments in favor of judgment)
Eastley v. Volkman, 132 Ohio St.3d 328, 972 N.E.2d 517 (standards on manifest-weight review)
State v. DeHass, 10 Ohio St.2d 230, 227 N.E.2d 212 (trial court's credibility determinations)