State v. Williams, 2020 Ohio 3269

On Nov. 20, 2018, Devon Williams fired 14 rounds from inside a market at a car parked by the entrance; the driver (S.P.) was shot, fled briefly, and died from his wounds.
Market and nearby surveillance videos captured Williams drawing a firearm, smiling, stepping to the door, and firing within seconds; other cameras recorded the victim and passenger fleeing.
Williams was indicted for murder (R.C. 2903.02(A) and (B)), two counts of felonious assault, attempted murder, carrying a concealed weapon, and multiple firearm specifications; he testified at trial claiming self‑defense based on three prior encounters with S.P.
The trial court (with the State’s acquiescence) instructed the jury under amended R.C. 2901.05(B), which requires the prosecution to disprove self‑defense beyond a reasonable doubt once the defendant presents evidence supporting it.
The jury convicted Williams on all counts and specifications; the court merged related counts and sentenced him to an aggregate term of 25 years to life; Williams appealed, arguing his convictions were against the manifest weight of the evidence because the State failed to disprove self‑defense.

Issue	State's Argument	Williams' Argument	Held
Whether convictions are against the manifest weight because the State failed to disprove self‑defense under amended R.C. 2901.05(B)	Video and other evidence showed Williams drew and fired in seconds, smiled before firing, and had no objectively reasonable belief of imminent danger; State disproved an element of self‑defense beyond a reasonable doubt	Williams relied on three prior threatening encounters and his subjective belief that S.P. had a gun that justified immediate use of deadly force	Affirmed. The court held the evidence did not weigh heavily against the verdict; the jury could reasonably conclude Williams’ belief was not objectively reasonable and that he was at fault in creating the affray

State v. Otten, 33 Ohio App.3d 339 (9th Dist. 1986) (standard for manifest‑weight review)
State v. Martin, 20 Ohio App.3d 172 (1st Dist. 1983) (reversal on manifest‑weight grounds reserved for exceptional cases)
State v. Robbins, 58 Ohio St.2d 74 (Ohio 1979) (elements of self‑defense)
State v. Cassano, 96 Ohio St.3d 94 (Ohio 2002) (self‑defense elements are cumulative)
State v. Jackson, 22 Ohio St.3d 281 (Ohio 1986) (burden and proof framework for affirmative defenses)
State v. Thomas, 77 Ohio St.3d 323 (Ohio 1997) (objective and subjective components of belief in imminent danger)
State v. Koss, 49 Ohio St.3d 213 (Ohio 1990) (defendant’s state of mind is crucial; prior conduct may be admissible to show it)
State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (prior acts cannot be introduced to prove victim was initial aggressor)
State v. Randle, 69 Ohio App.2d 71 (10th Dist. 1980) (evidentiary value and purpose of prior threats in self‑defense claims)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (courts must consider witness credibility in manifest‑weight review)