2024 Ohio 2171
Ohio Ct. App.2024Background
- Courtland Scales was convicted for the murder of D’Andre Rhone and the attempted murders of Donnie Walker and Mario Gay after two altercations at bars in 2021, culminating in Scales firing into a crowd, killing one and injuring two others.
- The altercations stemmed from an incident at Rollhouse Entertainment, where Scales had a physical confrontation with partygoers; later that night, a confrontation outside Unkut Lounge led to the shooting.
- Scales was indicted on multiple counts, including aggravated murder, murder, attempted murder, felonious assault, discharge of a firearm near prohibited premises, and having weapons while under disability.
- The jury convicted Scales on all counts submitted to it; after merger of allied offenses, the court sentenced him to an aggregate of 33 years to life in prison.
- On appeal, Scales challenged the sufficiency and weight of the evidence for his convictions, raised self-defense, asserted ineffective assistance of counsel, and claimed error in the denial of jury instructions for inferior offenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for murder/attempted murder | Evidence showed purposeful intent by firing into a group, hitting individuals | Scales was firing to escape perceived danger, not with intent to kill or harm | Sufficient evidence supported purposeful intent; conviction affirmed |
| Manifest weight of the evidence/self-defense | Scales created and escalated the situation, used deadly force when perceived threat was fleeing | Scales acted in self-defense after seeing a security guard reach for a firearm | Jury properly rejected self-defense; conviction not against manifest weight |
| Ineffective assistance of counsel (re: witness's reference to intimidation) | Counsel’s choices were reasonable trial strategy, no prejudice shown | Not requesting a curative instruction or mistrial prejudiced defense | No deficient performance or prejudice; not ineffective assistance |
| Jury instructions on voluntary manslaughter/aggravated assault | No evidence of rage or passion to support instruction; only self-defense asserted | Trial court erred in not instructing on inferior offenses | No abuse of discretion; instructions properly denied given self-defense theory |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (standard for sufficiency of evidence in criminal convictions)
- State v. Carter, 72 Ohio St.3d 545 (intent inferred from shooting into a group)
- State v. Seiber, 56 Ohio St.3d 4 (firearms as inherently dangerous; shooting into crowd infers intent)
- State v. Williamson, 8th Dist. Cuyahoga No. 95732, 2011-Ohio-4095 (purposeful shooting into a group)
- State v. Wolons, 44 Ohio St.3d 64 (standard for appellate review of refusal to give jury instruction)