State v. Williams, 2019 Ohio 5381

On June 17, 2017, inmate Kent D. Williams got into an altercation with corrections officer Tyler Dunlap and officer Lindsey McCoy at Allen–Oakwood Correctional Institution; a video of the incident was admitted at trial.
Williams was indicted on two counts of third-degree felony assault (R.C. 2903.13) and pleaded not guilty; the case was tried to the bench on May 6, 2019.
The trial court found Williams guilty on both counts; on June 17, 2019 the court sentenced him to two consecutive 9‑month terms (18 months aggregate), consecutive to a prison term in another case.
At trial McCoy testified Williams refused orders to return to his cell, adopted an aggressive stance, and struck McCoy and Dunlap; Williams testified officers tackled him, Dunlap put him in a choke hold, and he struck Dunlap with a radio in self‑defense.
Other inmate witnesses provided limited or mixed corroboration; Williams argued on appeal that his convictions were unsupported by sufficient evidence and were against the manifest weight because he acted in self‑defense.
The Third District affirmed: it treated self‑defense as an affirmative defense (burden on defendant), concluded Williams had created the situation by refusing orders, and held the officers were permitted to use less‑than‑deadly force, so Williams failed to prove self‑defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether convictions were supported by sufficient evidence and whether they were against the manifest weight because Williams acted in self‑defense	State argued the evidence, including video and McCoy's testimony, established the assaults and that Williams failed to meet the elements of self‑defense	Williams argued he acted in self‑defense after officers tackled him and Dunlap placed him in a choke hold; he hit Dunlap with a radio to protect himself	Affirmed: sufficiency upheld; manifest‑weight review found Williams failed to prove self‑defense because he was at fault for creating the affray by refusing orders, permitting officers to use less‑than‑deadly force

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest‑weight standards)
State v. Jenks, 61 Ohio St.3d 259 (1981) (standard for reviewing sufficiency of the evidence)
State v. DeHass, 10 Ohio St.2d 230 (1967) (trial court given discretion on witness credibility and weight of evidence)
State v. Jackson, 22 Ohio St.3d 281 (1986) (defendant must prove elements of self‑defense by preponderance)
State v. Hancock, 108 Ohio St.3d 57 (2006) (affirmative defenses do not negate the elements the prosecution must prove)
Columbus v. Fraley, 41 Ohio St.2d 173 (1975) (private citizen may not use force to resist a known authorized officer unless officer uses excessive force)
State v. Hunter, 131 Ohio St.3d 67 (2011) (appellate reversal for manifest‑weight error is limited to exceptional cases)