State v. Reid, 135 N.E.3d 517

Background

On June 27, 2015, Yolanda Reid stabbed and killed her boyfriend, Melvin Hill; she was indicted for murder under R.C. 2903.02(A) and (B).
Reid claimed self-defense; evidence included a 911 call (Reid reporting Hill had put hands on her), Reid’s post-arrest interview (admitting the stabbing and describing prior assaultive conduct by Hill), and eyewitness testimony from three of Hill’s relatives with inconsistent statements.
The trial court instructed the jury on self-defense, the duty to retreat, and the former statutory rebuttable presumption of self-defense for unlawful entry, but did not give a separate jury instruction on the castle doctrine (R.C. 2901.09).
Defense counsel repeatedly told the jury in closing that Reid had no duty to retreat in her own home and that a castle-doctrine instruction would be given; the court did not give that instruction.
The jury acquitted Reid of murder under R.C. 2903.02(A) but convicted her under R.C. 2903.02(B) (felony murder) and sentenced her to 15 years to life.
On appeal, the First District reversed, holding counsel rendered ineffective assistance by failing to request a castle-doctrine instruction and that Reid was prejudiced thereby; remaining claims were rendered moot. A dissent would have found no prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to request a castle-doctrine (R.C. 2901.09) jury instruction	State argued conviction should stand (prosecutor contended duty-to-retreat instruction was proper and case facts undercut self-defense)	Reid argued counsel was deficient for not requesting castle-doctrine instruction and that omission prejudiced her because she had no duty to retreat in her home	Court held counsel was deficient and Reid was prejudiced; reversed and remanded
Whether the jury should have been instructed that a person lawfully in their residence has no duty to retreat before using force	State maintained the court’s given duty-to-retreat instruction and rebuttable-presumption instruction were sufficient	Reid maintained evidence showed the confrontation occurred in her apartment and the jury should have been told she had no duty to retreat	Court held omission of explicit castle-doctrine instruction was error because evidence warranted it and the jury could be misled by existing instructions
Whether the failure to give a castle-doctrine instruction was harmless	State argued strength of its evidence (inconsistent testimony, Reid’s statements) made a different outcome unlikely	Reid argued repeated defense statements promising such an instruction and prosecutor’s contrary argument made omission prejudicial	Court held there was a reasonable probability of a different outcome and that Reid was prejudiced; reversal required

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (establishing deficient-performance and prejudice standard for ineffective assistance)
State v. Bradley, 42 Ohio St.3d 136 (Ohio standard applying Strickland)
State v. Williford, 49 Ohio St.3d 247 (defendant entitled to complete jury instructions on issues raised by the evidence)
State v. Jackson, 22 Ohio St.3d 281 (elements of self-defense are cumulative)
State v. Lewis, 976 N.E.2d 258 (distinguishing castle doctrine from the rebuttable-presumption statute)