State v. Tyra, 2017 Ohio 313

Victim Triston McDonald went to meet defendant Phillip Tyra (identified as "Gates") to buy marijuana on May 27, 2015; Tyra entered McDonald’s car and McDonald was shot four times and died at the scene.
Tyra was indicted on four counts of murder, two counts of aggravated robbery, two counts of felonious assault (all with firearm specifications), carrying a concealed weapon, and trafficking in marijuana; tried Jan. 2016.
Jury convicted Tyra of two counts of murder, two counts of felonious assault (each with a firearm specification), carrying a concealed weapon, and trafficking in marijuana; acquitted on two murder counts and two aggravated robbery counts.
Trial evidence: Tyra admitted shooting McDonald, claimed self-defense (said McDonald pulled a gun); forensics showed four shots from the same .38-class gun found on the passenger floorboard; McDonald’s defensive wound but the gun in the car was not McDonald’s.
Tyra fled the scene, did not call police, later left town for days; detectives recorded two interviews in which Tyra admitted facts but his account conflicted with physical evidence.
Trial court merged sentences and imposed aggregate 20 years and six months to life; Tyra appealed raising weight-of-evidence, exclusion of victim’s past conduct, and Confrontation Clause issues relating to interrogation videos.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Tyra)	Held
Manifest weight of the evidence	Conviction supported; jury reasonably rejected self-defense given physical and forensic evidence and Tyra’s admissions	Tyra’s account was equally plausible; convictions against the manifest weight of the evidence	Affirmed — jury did not lose its way; weight supported convictions
Exclusion of victim’s criminal history/reputation	Irrelevant to Tyra’s state of mind because Tyra had only met victim once and had no knowledge of any record	Evidence of victim’s past conduct was relevant to justify Tyra’s claimed state of mind for self-defense	Affirmed — no plain error; defendant waived objection at trial and relevance lacking
Admission of interrogation videos (detectives’ statements)	Videos admissible; detectives’ comments not offered for truth and jury instructed to consider only defendant’s statements	Detectives’ participatory comments were testimonial hearsay implicating Confrontation Clause since some detectives did not testify	Affirmed — court properly instructed jury; detectives’ remarks not hearsay and no confrontation violation
Standard of review for in limine ruling	Preliminary ruling; objections must be timely preserved for appellate review	Trial court’s motion-in-limine ruling violated due process if excluded defense evidence	Rejected — interlocutory in limine ruling not reviewable absent timely objection or plain error; no plain error shown

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for manifest-weight review)
State v. Martin, 20 Ohio App.3d 172 (1st Dist.) (foundational discussion of weight review principles)
State v. DeHass, 10 Ohio St.2d 230 (1967) (jury may believe or disbelieve testimony; credibility deference)
State v. Grubb, 28 Ohio St.3d 199 (1986) (motion in limine is tentative; finality requires trial context)
State v. Long, 53 Ohio St.2d 91 (1978) (plain-error doctrine; caution in noticing plain error)
State v. Noling, 98 Ohio St.3d 44 (2002) (trial court’s evidentiary rulings reviewed for abuse of discretion)
State v. Baker, 170 Ohio App.3d 331 (2d Dist.) (motion-in-limine rulings and waiver by failing to object at trial)