State v. Oates, 2013 Ohio 2609

Oates was indicted for assault of a school teacher on school premises in violation of R.C. 2903.13(A)/(C)(2)(e), a fifth-degree felony.
Trial proceeded to a jury, which found Oates guilty on November 5, 2012.
On December 13, 2012, the trial court sentenced him to one year of community control through the Community Corrections Department, including no contact with Ludwig and no attendance at Kenton City Schools athletic events.
Oates appeals, arguing ineffective assistance of counsel and that the community-control condition is overbroad and unnecessarily infringes liberty.
The appellate court reviews ineffective assistance of counsel under Strickland and community-control sanctions for abuse of discretion, upholding the sentence and conditions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
IAC claim—counsel's failure to request self-defense instruction	Oates argues trial counsel failed to request self-defense and did not review proposed instructions.	Oates contends counsel's performance was deficient and prejudicial because a self-defense instruction could have changed the outcome.	No deficient performance or prejudice; self-defense not raised by evidence; assignment overruled.
Validity of a broad community-control condition	Oates contends banning attendance at all Kenton City Schools athletic events is overbroad and infringes liberty.	State argues condition reasonably relates to rehabilitating and preventing future misconduct.	Condition not abusively broad; reasonably related to crime, rehabilitation, and future conduct; assignment overruled.

State v. Kole, 92 Ohio St.3d 303 (2001) (test for ineffective assistance—deficient performance and prejudice)
Strickland v. Washington, 466 U.S. 668 (1984) (defining two-prong test for ineffective assistance)
State v. Bradley, 42 Ohio St.3d 136 (1989) (reasonable probability standard for prejudice)
State v. Lytle, 48 Ohio St.2d 391 (1976) (trial-venue standards and appellate review principles)
State v. Clayton, 62 Ohio St.2d 45 (1980) (jury instruction standards and applicability)
State v. Fritz, 163 Ohio App.3d 276 (2005) (instructions must map to actual issues and evidence)
State v. Melchior, 56 Ohio St.2d 15 (1978) (self-defense evidentiary standard and instruction guidance)
State v. Densmore, 2009-Ohio-6870 (2009) (self-defense elements and burden of proof)
State v. Williams, 2008-Ohio-6637 (2008) (self-defense elements and evidentiary standards)
State v. Kimmell, 2011-Ohio-660 (2011) (elements of self-defense for non-deadly force)
Coleman v. Coleman, 2006-Ohio-3200 (2006) (probation/conditions—relationship to crime and rehabilitation)
Jones v. State, 49 Ohio St.3d 1 (1990) (commonsense approach to probation conditions and notice)
Westrick v. State, 196 Ohio App.3d 141 (2011) (probation conditions must be reasonably related to ends of probation)
Talty v. State, 2011-Ohio-1169 (2011) (broad discretion in imposing community-control sanctions)