State v. Steinhauer, 2014 Ohio 1981

Appellant Thomas H. Steinhauer was convicted by a jury on ten counts, including Aggravated Murder, in the Scioto County Court of Common Pleas; he appeals the court’s denial of a self-defense jury instruction and the denial of admission of relevant victim-character evidence.
Indictment filed March 23, 2012 charging Aggravated Murder (two counts), Murder, Aggravated Arson, Arson, Tampering With Evidence (three counts), Kidnapping, and Conspiracy to Aggravated Murder/Murder.
The victim, Felipe Lopez, a former drug associate, died March 7, 2012; the events involved Steinhauer and two co-defendants with weapons including a knife and a hatchet.
DNA testing linked Lopez to the knife and hatchet; autopsy attributed death to multiple stab/chop wounds with inhalation injury from the fire as a contributing factor.
The State’s theory was that Steinhauer, Gerald, and Linkous planned Lopez’s murder; trial evidence included pre‑March 7 discussions about killing Lopez; the jury found Steinhauer guilty, and he was sentenced to life without parole plus 29 years.
On appeal, Steinhauer argues (1) denial of a self-defense instruction violated due process and (2) denial of admission of victim’s character evidence prejudiced him; the appellate court overrules both arguments and affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Self-defense instruction required?	Steinhauer; entitlement to self-defense instruction.	State; instruction not warranted due to prior planning to kill.	No abuse of discretion; instruction not required.
Admission of victim’s character evidence?	Steinhauer allowed to present specific prior violence of Lopez to show state of mind.	State’s evidence of Lopez’s violence and traits not admissible; Barnes limits on proving aggressor.	No reversible error; court properly admitted/limited evidence.

State v. Hamilton, 2011-Ohio-2783 (4th Dist. Scioto No. 09CA3330 (2011)) (jury instruction standard; trial court discretion)
State v. Comen, 50 Ohio St.3d 206 (Ohio (1990)) (mandatory instruction content requirement; complete charging required)
State v. Mitts, 81 Ohio St.3d 223 (Ohio (1998)) (court can determine sufficiency of evidence for instruction)
State v. Wolons, 44 Ohio St.3d 64 (Ohio (1989)) (abuse of discretion standard in evidentiary rulings)
State v. Barnes, 94 Ohio St.3d 21 (Ohio (2002)) (limits on specific instances to prove victim’s aggressor; state of mind rationale)
State v. Goff, 2013-Ohio-42 (4th Dist. No. 11CA20 (2013)) (self-defense instruction standard of review and evidence sufficiency)