State v. Staats, 2021 Ohio 1325

Victim (Jane Doe), age 18, lived with appellant Drew Staats in his grandmother’s house; they argued on June 29–30, 2019.
On June 30 Doe testified Staats repeatedly pushed her onto the bed, pushed her into a pole and a filing cabinet, causing bruises; she called police the next day and the deputy photographed injuries and took statements.
Staats admitted pushing Doe repeatedly to get her “out of his face,” denied causing the bruises and asserted he would not hit females; he did not request a self-defense instruction at trial.
Staats was charged with one count of domestic violence (R.C. 2919.25(A)), tried by jury, convicted, and sentenced to 180 days with most suspended, anger-management and no-contact conditions.
On appeal Staats raised three assignments of error: (1) trial court erred by not giving a self-defense instruction, (2) ineffective assistance of counsel for failing to request that instruction, and (3) conviction was against the sufficiency and manifest weight of the evidence.
The Fifth District Court of Appeals affirmed the conviction, rejecting each assignment of error.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Staats)	Held
Whether the trial court erred by not instructing the jury on self-defense	No error; evidence did not tend to support self-defense so no instruction required	Trial testimony that Doe attacked him and he pushed only to defend himself warranted a self-defense instruction under amended R.C. 2901.05	No plain error: record lacked sufficient evidence that Staats honestly and reasonably believed he faced imminent bodily harm, so instruction not warranted
Whether trial counsel was ineffective for failing to request a self-defense instruction	Counsel’s choices were reasonable because self-defense was unsupported by the evidence	Counsel was ineffective for failing to request the instruction, which would have shifted burden to state under amended law	No ineffectiveness: failure to request the instruction was not deficient because the instruction was not warranted by the evidence, so no prejudice under Strickland
Whether the conviction is supported by sufficient evidence and against the manifest weight	Evidence (victim testimony, deputy’s observations, photos) established that Staats knowingly caused physical harm to a household member	Challenges included minor bruising, delay in reporting, and claimed self-defense	Affirmed: viewing evidence in favor of the prosecution sufficiency met; jury credibility determination reasonable and conviction not against manifest weight

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong test for ineffective assistance of counsel)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for sufficiency of the evidence)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest‑weight review and its distinction from sufficiency)
State v. Melchior, 56 Ohio St.2d 15 (Ohio 1978) (evidence required to raise affirmative defenses for jury instruction)
State v. Sneed, 63 Ohio St.3d 3 (Ohio 1992) (defendant entitled to complete jury instructions on issues raised by evidence)
State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (plain‑error standard under Crim.R. 52(B))
Neder v. United States, 527 U.S. 1 (U.S. 1999) (harmless error/materiality principles)
State v. Cunningham, 105 Ohio St.3d 197 (Ohio 2004) (harmless‑error context for constitutional errors)
State v. Yarbrough, 95 Ohio St.3d 227 (Ohio 2002) (credibility determinations are for the trier of fact)
State v. Jacinto, 155 N.E.3d 1056 (Ohio App. 2020) (interpretation of amended R.C. 2901.05 burden when self‑defense evidence is presented)