State v. Schooler, 2018 Ohio 3295

On Feb. 28, 2016, Daniel G. Schooler shot and killed his brother William in the pastor’s office at St. Peter’s Missionary Baptist Church; police found a Kel‑Tec .380 at the scene and five rounds of matching ammunition in Schooler’s pocket.
Schooler was arrested at the church, admitted he was the shooter, and testified he went to confront William about an inheritance dispute and shot in self‑defense after William allegedly advanced on him.
Autopsy showed four gunshot wounds to William (three bullets recovered from the body) including a fatal aortic wound; crime scene evidence and spent casings indicated five shots were fired.
Schooler was indicted for aggravated murder (reduced by the jury to purposeful murder), two counts of felony murder, two counts of felonious assault, firearm and repeat violent offender specifications, and two counts of having weapons under disability; he was found guilty on most counts and specifications.
The trial court found Schooler competent to stand trial after three forensic evaluations and a competency hearing; Schooler was sentenced to an effective 31 years to life (merged counts and specifications applied).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competence to stand trial	State: Schooler was competent; court relied on two defense‑expert disagreements with defendant’s expert and found sufficient evidence of competence.	Schooler: his history of delusions and mental illness prevented him from understanding proceedings or assisting counsel.	Court affirmed competence finding: two State experts provided reliable, credible evidence that Schooler had factual and rational understanding and could assist counsel.
Manifest weight / self‑defense	State: physical and testimonial evidence contradicts self‑defense; Schooler created the violent situation and failed to prove bona fide fear or duty to retreat.	Schooler: he acted in self‑defense because William advanced on him and he felt trapped in the office.	Court held verdicts were not against the manifest weight of the evidence: jury reasonably discredited self‑defense given admissions, physical evidence, number/trajectories of wounds, and other testimony.

State v. Neyland, 139 Ohio St.3d 353 (Ohio 2014) (competency standard follows Dusky test: factual and rational understanding and ability to assist counsel)
State v. Berry, 72 Ohio St.3d 354 (Ohio 1995) (competency standard articulation)
Dusky v. United States, 362 U.S. 402 (U.S. 1960) (establishes competence-to-stand-trial test)
State v. Were, 118 Ohio St.3d 448 (Ohio 2008) (trial court’s competence finding will be upheld if supported by reliable, credible evidence)
State v. Jordan, 101 Ohio St.3d 216 (Ohio 2004) (burden on defendant to prove incompetence by preponderance)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for reviewing manifest-weight claims)
Tibbs v. Florida, 457 U.S. 31 (U.S. 1982) (appellate court acting as thirteenth juror when reviewing weight of evidence)
State v. Williford, 49 Ohio St.3d 247 (Ohio 1990) (elements of self‑defense, including duty to retreat when deadly force used)