State v. Walker (Slip Opinion), 150 Ohio St. 3d 409

Early-morning bar fight at Tavo Martini Lounge; surveillance video from multiple cameras captured the melee.
Victim Antwon Shannon and companion Ivor Anderson were involved in the fight begun when Robert Steel struck Anderson with a champagne bottle.
Dajhon Walker joined the fight, struck Shannon, retreated behind a pillar and was out of camera view for ~20 seconds; a gunshot then occurred and Shannon was shot in the back and later died.
Walker was indicted and convicted of aggravated murder, felony murder, felonious assault counts, and weapons offenses; sentenced to 25 years to life.
The Eighth District reversed Walker’s aggravated-murder conviction for insufficient evidence of prior calculation and design but upheld felony-murder conviction; this Court affirmed the appellate court regarding aggravated murder and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported aggravated murder element of "prior calculation and design"	State: video and conduct (withdrawing behind pillar, reaching waistband, coordinated attack) allowed reasonable inference of planning during ~20-sec absence	Walker: killing arose from spontaneous escalation of a bar fight; no evidence of prior plan, choice of site, or weapon preparation	Insufficient evidence of prior calculation and design; aggravated-murder conviction vacated
Whether felony-murder conviction was supported	State: death proximately resulted from underlying felony (felonious assault) and Walker knowingly caused harm	Walker: not argued to negate felony-murder here	Felony-murder conviction upheld
Proper standard of appellate review for sufficiency	State: review must view evidence in light most favorable to prosecution and draw reasonable inferences for state	Appellate court applied Taylor factors but concluded insufficient; dissent argued appellate court failed to defer to jury	Majority applied sufficiency standard but concluded evidence did not permit reasonable inference of prior calculation and design
Whether purpose alone satisfies aggravated-murder mens rea	State: evidence of purpose present but must also show prior calculation and design	Walker: purpose does not equal prior calculation and design; momentary deliberation insufficient	Court reiterated that purpose ≠ prior calculation and design; both required for aggravated murder

State v. Jenks, 61 Ohio St.3d 259 (establishes Jackson v. Virginia sufficiency standard under Ohio law)
Jackson v. Virginia, 443 U.S. 307 (constitutional sufficiency standard for criminal convictions)
State v. Taylor, 78 Ohio St.3d 15 (sets guiding factors for prior calculation and design inquiry)
State v. Cotton, 56 Ohio St.2d 8 (explains that instantaneous deliberation is insufficient for prior calculation and design)
State v. Palmer, 80 Ohio St.3d 543 (held short time can suffice when defendant adopted plan and executed it with precision)
State v. Maxwell, 139 Ohio St.3d 12 (reaffirming no bright-line test; Cotton framework)
State v. Conway, 108 Ohio St.3d 214 (pursuing and killing a fleeing or incapacitated victim supports prior calculation and design)