State v. Tuggle, 2023 Ohio 3965

Defendant Sharonda Tuggle was convicted after a bench trial of murder and felonious assault for the stabbing death of her boyfriend, L.S.; convictions merged and she was sentenced to 15 years to life.
At the scene officers found L.S. lying in a blood-saturated bathroom floor with a knife nearby; Tuggle had blood on her clothes and gave multiple, inconsistent statements (including telling 9‑1‑1 that he fell or had stabbed himself).
Autopsy showed multiple incised/stab wounds, including a fatal chest stab perforating the right ventricle; manner of death ruled homicide.
Forensic testing showed L.S.’s DNA on the knife blade; the handle contained a mixture with Tuggle as a major contributor; crime‑scene photos showed damage to the outside of the bathroom door and blood primarily on the outside and floor.
Tuggle testified she and L.S. fought, he took a knife into the bathroom and tried to lock the door, they struggled through the door, she grabbed the knife and stabbed him as he charged; she gave multiple different accounts to police and denied self‑defense until late in interview.
The trial court found the State disproved self‑defense beyond a reasonable doubt; on appeal the Sixth District affirmed, finding the verdict not against the manifest weight of the evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Tuggle)	Held
Whether the trial court erred in finding the State disproved Tuggle's claim of self‑defense beyond a reasonable doubt	Tuggle created the affray (pounding on door, escalating); did not honestly believe she faced imminent death or great bodily harm; used excessive, disproportionate deadly force; multiple inconsistent statements undermine credibility	L.S. had the knife, confronted her through the bathroom door, charged at her, she met her low initial burden of production and acted in self‑defense	Affirmed. Court credited State's evidence and credibility findings; concluded the verdict was not against the manifest weight of the evidence and self‑defense was disproved

State v. Barnes, 759 N.E.2d 1240 (Ohio 2001) (elements for use of deadly force in self‑defense)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (standard for manifest‑weight review)
State v. Martin, 485 N.E.2d 717 (Ohio Ct. App. 1984) (reversal on manifest‑weight grounds reserved for exceptional cases)
State v. Thomas, 673 N.E.2d 1339 (Ohio 1997) (bona fide belief is both subjective and objective; proportionality of force)
State v. Guice, 133 N.E.3d 874 (Ohio Ct. App. 2019) (accident and self‑defense are generally inconsistent defenses)
State v. Barker, 199 N.E.3d 626 (Ohio Ct. App. 2022) (force must be reasonably necessary; disproportional force negates self‑defense)
In re N.K., 180 N.E.3d 78 (Ohio Ct. App. 2021) (R.C. 2901.05(B)(1) and burden‑of‑production principles for self‑defense)