State v. Wilder, 58 N.E.3d 421

Defendant Moses D. Wilder was indicted on one count of third-degree felony domestic violence and one count of first-degree felony rape arising from an incident on January 7, 2015; Wilder admitted intercourse but claimed it was consensual.
Victim testified Wilder assaulted, choked, threatened to kill her and her family, forced her into a hotel room and penetrated her; she later sought help, had observable injuries, and signed a domestic-violence complaint.
Police officers, a detective, and a SANE nurse testified regarding the victim’s appearance, injuries, and Wilder’s statement that intercourse occurred and that he suspected her of cheating.
Trial court denied Wilder’s challenges for cause to a juror (who was later removed by a peremptory), allowed limited questioning referencing "battered spouse syndrome," and denied Wilder’s requested "reverse flight" jury instruction.
Jury convicted Wilder on both counts; trial court imposed an aggregate 10.5-year prison sentence. Wilder appealed raising four assignments of error (juror challenge, battered-spouse testimony, manifest-weight challenge, and jury instruction refusal).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Wilder)	Held
Denial of challenge for cause to Juror Walsh	Juror could be impartial; voir dire showed ability to be fair	Juror had relationship to officer and expressed difficulty being impartial; should be excused for cause	Trial court did not abuse discretion; juror said he could be fair and was removed by peremptory, no prejudice shown
Admission/mention of battered-spouse syndrome	Limited reference was relevant to victim’s state of mind to explain conduct after assault	Single offhand prosecutorial reference was prejudicial and should have been excluded	No prejudicial error: reference was not testimony, no expert or jury instruction about syndrome, and defendant did not seek striking it
Manifest weight of the evidence	Evidence (victim testimony, officer and SANE observations, Wilder’s statement) supports convictions	Victim’s conduct (remaining with Wilder, entering room) undermines credibility; convictions against manifest weight	Convictions were not against the manifest weight; jury reasonably credited the victim and other testimony
Refusal to give "reverse flight" instruction	No requirement to give a reverse-flight/modified O.J.I. instruction; optional instruction need not be inverted	Requested instruction would show consciousness of innocence for failure to flee	Trial court did not abuse discretion in refusing the modified instruction; refusal not prejudicial

State v. Trimble, 122 Ohio St.3d 297 (trial court has broad discretion in juror impartiality determinations)
State v. White, 82 Ohio St.3d 16 (deference to trial judge who sees and hears juror)
Wainwright v. Witt, 469 U.S. 412 (same principle on juror bias)
Gray v. Mississippi, 487 U.S. 648 (prejudice inquiry focuses on jury panel as a whole)
State v. Broom, 40 Ohio St.3d 277 (defendant must exhaust peremptories and show partial juror to state constitutional violation)
State v. Williams, 79 Ohio St.3d 1 (erroneous denial of cause can be prejudicial if it forces use of peremptory)
State v. Haines, 112 Ohio St.3d 393 (permitted use of battered-spouse evidence to explain victim behavior)
State v. Thompkins, 78 Ohio St.3d 380 (standard for manifest-weight review)
State v. Mendoza, 137 Ohio App.3d 336 (appellate standard describing manifest-weight review)
State v. Scott, 26 Ohio St.3d 92 (error to refuse a correctly-stated, pertinent jury charge)
State v. Sneed, 63 Ohio St.3d 3 (defendant entitled to complete and accurate instructions on issues raised by evidence)
State v. Nadock, 11 Ohio App.3d 2009-L-042 (trial court caution on non-standard jury instructions)