State v. Williams, 2012 Ohio 5256

Appellant Rassol Hassan Williams was convicted of murder and having a weapon while under a disability after shooting Charles King during an argument in Steubenville, Ohio.
Witnesses May and Frye observed the assault; King was shot five times and died; bullets were .380 FMJ, with a box of the same bullets found at Williams's home bearing his fingerprint; the murder weapon was not recovered.
Williams testified that he feared King due to prior threats and claimed self-defense; the State presented multiple witnesses contradicting his account, and no other gun was found.
Williams pursued trial with self-defense theory; the jury found him guilty on both murder and the firearm specification; the court sentenced him to life with parole eligibility after 20 years, plus related counts.
On appeal, Williams argues the court should have instructed on voluntary manslaughter and that the verdict is against the manifest weight of the evidence.
The appellate court affirms, ruling that self-defense instruction was appropriate, voluntary manslaughter instruction was not warranted, and the weight of the evidence supports the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Manifest weight/sufficiency of evidence	Williams contends conviction against manifest weight; self-defense theory undermines guilt.	State argues evidence supports guilt; self-defense not proven by Williams.	Conviction not against manifest weight; sufficient evidence supports self-defense claim not established.
Instruction on voluntary manslaughter	Williams asserts entitlement to voluntary manslaughter instruction.	State argues manslaughter instruction incompatible with self-defense; no evidence of sudden passion or rage.	No voluntary manslaughter instruction required; evidence did not show sudden passion or rage.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for weight of the evidence; 13th juror concept)
State v. Eley, 56 Ohio St.2d 169 (1978) (reasonable doubt standard; credibility of witnesses)
State v. Robbins, 58 Ohio St.2d 74 (1979) (self-defense elements and retreat doctrine)
State v. Griffin, 2002-Ohio-6900 (7th Dist. 2002) (jury credibility decisions allowed; self-defense evidence not required to be believed)
State v. Marcum, 7th Dist. No. 04 CO 66, 2006-Ohio-7068 (2006) (self-defense vs. voluntary manslaughter compatibility)
State v. Kaufman, 187 Ohio App.3d 50 (2010) (abuse of discretion standard for jury instructions)
State v. Shane, 63 Ohio St.3d 630 (1992) (inferior offense of voluntary manslaughter; provocation analysis)
Goldfuss v. Davidson, 79 Ohio St.3d 116 (1997) (self-defense burden of proof; affirmative defense standard)
State v. Lewers, 2010-Ohio-5336 (5th Dist. 2010) (conditions for instruction on inferior degree offense)