State v. Schooler, 2020 Ohio 4327

Incident on Sept. 11, 2019 in an apartment rental office: Kim Schooler sprayed Elaine Washington with mace/pepper spray; Washington suffered eye swelling and pain.
Washington testified she stayed far away, did not speak to or threaten Schooler, and did not reach into a pocket before being sprayed.
Office secretary Litisha Thompson testified the women were 4–5 feet apart, Washington asked why Schooler was "messing" with Keisha, did not threaten or touch Schooler, and Schooler sprayed Washington while angry.
Schooler testified Washington got in her face, reached into her pocket, and she sprayed in self-defense; Burton testified Schooler had earlier threatened Keisha.
Defense attempted to impeach Washington with a prior inconsistent statement reported to a public defender investigator; the court sustained a hearsay objection to questioning Washington directly but allowed the investigator to testify later.
Trial court acquitted Schooler of aggravated menacing and menacing, convicted her of misdemeanor assault, and imposed jail time (partially suspended), probation, psychological assessment, and a stay-away order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defense could impeach Washington on direct exam with her prior out-of-court statement to an investigator	The statement was hearsay if elicited through counsel; the investigator must testify to the prior inconsistent statement	The question was impeachment of Washington with her own prior statement, not hearsay	Trial court's hearsay ruling was at most harmless error because the investigator later testified to the same prior statement; no reversible error
Whether the trial court erred in excluding Washington's 2011 "abuse of 9-1-1" conviction under Evid.R. 609(A)(3)	The conviction involved dishonesty/false statement and was admissible for impeachment	Conviction did not necessarily involve dishonesty; defense presumed statute but record showed a municipal ordinance offense	Exclusion proper: the Dayton ordinance offense did not necessarily involve dishonesty; court did not abuse discretion in excluding it
Whether Schooler's assault conviction was against the manifest weight of the evidence (self-defense)	State: evidence (including Thompson) showed Schooler knowingly caused harm and lacked bona fide belief of imminent great bodily harm; no duty-to-retreat defense met	Schooler: she acted in self-defense because Washington got in her face and reached into a pocket	Affirmed. The trial court reasonably credited Thompson over Schooler; the evidence did not compel a finding of self-defense; conviction not against manifest weight

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for reviewing whether a verdict is against the manifest weight of the evidence)
State v. Martin, 20 Ohio App.3d 172 (Ohio 1983) (reversal on manifest-weight grounds is warranted only in the exceptional case)