State v. Travis, 2022 Ohio 1233

On Sept. 25, 2020, Sierra Travis and her boyfriend Hiriam Frazier left an apartment complex after a brief visit; surveillance footage captured events in the parking lot.
Travis retrieved a handgun from the rear passenger area of a shared rental Jeep, fired a “warning shot,” then walked around the car and shot Frazier in the chest.
Frazier was transported to the hospital and died; autopsy listed cause of death as a gunshot wound and manner homicide.
A grand jury indicted Travis on two murder counts and one felonious-assault count with firearm specifications; she waived a jury and elected a bench trial.
At trial Travis testified she acted in self-defense (and alternatively that the shooting was accidental); the state introduced surveillance, witness testimony, and forensic evidence.
The trial court rejected accident and self-defense theories, found Travis guilty on all counts, and sentenced her to an aggregate 18 years to life; the court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by not considering accident / providing accident instruction	State: court considered accident and explicitly referenced accident instruction language; no legal requirement to further explain in a bench trial	Travis: court failed to consider accident and should have instructed on it	Court: overruled — bench-trial presumption that the court applied the law; court cited accident instruction language and reasonably rejected accident theory
Whether the court should have instructed on or convicted of lesser included offense of reckless homicide	State: bench court is presumed to have considered lesser-included offenses; evidence supported murder	Travis: requested reckless-homicide instruction and argues conviction should have been on lesser offense	Court: overruled — presumption that bench court considered lesser included offenses and evidence supported murder
Whether Travis was entitled to acquittal on self-defense grounds	State: evidence (surveillance, witnesses) disproved self-defense; Travis created the situation and used excessive force	Travis: claimed she fired in response to being confronted and advanced upon; alternative claim of accidental discharge	Court: overruled — court found surveillance and testimony undermined self-defense, and trial court did not lose its way in making credibility findings

Walker v. State, 26 Ohio App.3d 29 (Ohio Ct. App. 1985) (bench-trial general-finding requirement under Crim.R. 23(C))
Thompkins v. Ohio, 78 Ohio St.3d 380 (Ohio 1997) (standard for reversing convictions as against the manifest weight of the evidence)