State v. Reyes-Figueroa, 2020 Ohio 4460

Background

Appellant Edwin Reyes-Figueroa and victim Jonathan Benitez-Machuca were coworkers; appellant reassigned Jonathan and an argument ensued after their shift.
Surveillance and eyewitnesses show the men left the factory together, followed by others who expected a fight; vehicles stopped on a side street.
Appellant exited his car, retrieved a handgun from his waistband, and fired multiple rounds at Jonathan; Jonathan suffered six gunshot wounds, mostly to his back.
Appellant and his passenger (his father‑in‑law, Ramon Caceres) left the scene; appellant later disposed of the gun and lied to police.
Appellant was indicted on aggravated murder (with prior calculation and design), murder, felonious assault, discharge of a firearm near prohibited premises, and tampering; a jury convicted him on all counts and firearm specifications.
Trial court sentenced appellant to an aggregate 28 years to life; appellant appealed raising four assignments of error (self‑defense instruction, ineffective assistance, sufficiency and manifest weight regarding prior calculation and design).

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Reyes‑Figueroa)	Held
1. Whether the court erred by refusing to instruct the jury on self‑defense	No adequate evidence that appellant used reasonable, proportionate force; instruction not warranted	Appellant presented evidence that victim reached behind his back and that appellant reasonably feared for his life; instruction required under amended R.C. 2901.05	Affirmed — trial court did not abuse discretion; evidence only generated speculation and lacked support that force was reasonable
2. Whether defense counsel rendered ineffective assistance by arguing self‑defense after instruction denial (arguing toward nullification)	Counsel’s continued self‑defense argument was improper and prejudicial	Counsel reasonably pursued strategy (seek jury nullification / preserve argument to negate prior calculation) and acted within trial strategy	Affirmed — counsel’s performance not deficient; strategy reasonable and not prejudicial
3. Sufficiency of the evidence that killing was with prior calculation and design (element of aggravated murder)	Evidence (strained relationship, following victim off site, retrieving gun, pause between shots, statements at scene, flight/disposal of gun) proves prior calculation and design	Shooting was spontaneous or in self‑defense; no premeditation	Affirmed — viewed in light most favorable to State, evidence sufficient to support prior calculation and design
4. Whether conviction is against manifest weight of the evidence (prior calculation and design)	Credible eyewitness and forensic evidence, appellant’s post‑shooting conduct, and inconsistencies in appellant’s account support verdict	Jury should have found self‑defense or at least reasonable doubt about premeditation	Affirmed — not an exceptional case; jury did not lose its way; verdict supported by weight of evidence

Key Cases Cited

State v. Melchior, 56 Ohio St.2d 15, 381 N.E.2d 195 (defines standard for when a self‑defense instruction is warranted)
State v. Barnes, 94 Ohio St.3d 21, 759 N.E.2d 1240 (enumerates elements required to establish self‑defense)
Strickland v. Washington, 466 U.S. 668 (establishes standard for ineffective assistance of counsel)
State v. Taylor, 78 Ohio St.3d 15, 676 N.E.2d 82 (articulates factors for prior calculation and design)
State v. Walker, 150 Ohio St.3d 409, 82 N.E.3d 1124 (distinguishes spur‑of‑moment acts from premeditation)
State v. Coley, 93 Ohio St.3d 253, 754 N.E.2d 1129 (prior calculation can be found even when plan is quickly conceived and executed)
State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (sufficiency standard for criminal conviction)
State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (distinguishes sufficiency and manifest weight review)
State v. Conway, 108 Ohio St.3d 214, 842 N.E.2d 996 (a pause between shots may indicate intent to complete the killing)