State v. Wagner, 2015 Ohio 5183

Eventful July 31, 2014 bar confrontation between Wagner and his brother Timothy at Blue Eagle Bar in Bettsville, leading to a pool-stick assault.
Timothy reported vandalized sign by Wagner; sheriff advised restraint but Timothy confronted Wagner anyway.
On August 20, 2014, Wagner was indicted for domestic violence in violation of R.C. 2919.25(A),(D)(4), a third-degree felony.
Trial occurred March 2–3, 2015; jurors convicted Wagner and found he failed to prove self-defense by a preponderance.
Wagner was sentenced April 16–17, 2015; he timely appealed May 14, 2015 raising self-defense as the basis to reverse the conviction.
The court analyzed whether self-defense could negate the domestic-violence conviction under the manifest-weight standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction is manifestly unsupported where self-defense was proven by Wagner	Wagner argues self-defense was proven by preponderance, so conviction weighs against evidence.	State argues self-defense failed and the weight of evidence supports the conviction.	Conviction affirmed; self-defense not proven by weight of evidence.

State v. Vasquez, 2014-Ohio-224 (Ohio Ct. App. 10th Dist. 2014) (affirmative defenses do not implicate due process sufficiency)
State v. Belanger, 2010-Ohio-5407 (Ohio App.3d 2010) (self-defense burden on defendant by preponderance)
State v. Hancock, 108 Ohio St.3d 57 (2006-Ohio-160) (affirms handling of affirmative defenses and sufficiency standards)
State v. Bagley, 2014-Ohio-1787 (Ohio 3d Dist. 2014) (manifest-weight review respects juror credibility)
State v. Suffel, 2015-Ohio-222 (Ohio 3d Dist. 2015) (weighing evidence and credibility on manifest-weight review)
State v. Phillips, 2014-Ohio-5162 (Ohio 2014) (gestures toward credibility in appellate weight review)
State v. DeHass, 10 Ohio St.2d 230 (1967) (establishes standard for credibility and weight in review)
State v. Gillespie, 172 Ohio App.3d 304 (2007-Ohio-3439) (first-hand witness demeanor affects weight decisions)
State v. Kimmell, 2011-Ohio-660 (Ohio 3d Dist. Wyandot 2011) (elements of non-deadly self-defense; bona fide belief and reasonableness)
State v. Williams, 2008-Ohio-6637 (Ohio 7th Dist. 2008) (self-defense standard; non-deadly force considerations)