State v. Williams, 2023 Ohio 1903

On April 26–27, 2020, Kenneth Williams and his long‑time friend Cory Wilburn drank heavily and argued in the Harbor Crest apartment parking lot in Euclid, Ohio.
Williams threw a single punch that knocked Wilburn to the ground; Wilburn then stumbled, struck his head on pavement, and suffered an acute subdural hematoma, subarachnoid hemorrhage, and a skull fracture; he remains in a rehabilitation facility.
A neighbor (Strikwerda) observed the altercation from an eighth‑floor balcony, testified Williams was the more physically aggressive party, and called 911; surveillance footage corroborated some testimony.
Williams claimed the punch was defensive—he sought to stop an intoxicated Wilburn from driving—and gave statements to family and police to that effect.
After a bench trial, the court convicted Williams of aggravated assault (an inferior offense to felonious assault) and sentenced him to six months’ imprisonment; Williams appealed arguing the conviction was against the manifest weight of the evidence because of self‑defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction is against the manifest weight of the evidence because Williams acted in self‑defense	State: it disproved self‑defense beyond a reasonable doubt; eyewitnesses and surveillance show Williams was the primary aggressor	Williams: he presented evidence (his statements) that he punched once to prevent an intoxicated Wilburn from driving and acted to defend himself	Court: Affirmed. The state negated self‑defense (Williams was at fault in creating the affray); conviction not against manifest weight

State v. Thompkins, 78 Ohio St.3d 380 (1997) (sets the standard for manifest‑weight review)
State v. Wilson, 113 Ohio St.3d 382 (2007) (explains aggravated assault as an inferior offense to felonious assault)
State v. Martin, 20 Ohio App.3d 172 (1983) (describes weighing evidence and credibility on manifest‑weight review)
State v. Triplett, 192 Ohio App.3d 600 (2011) (single punch can be nondeadly force)
State v. Jacinto, 155 N.E.3d 1056 (2020) (treats a single punch as nondeadly force in the self‑defense context)
State v. Davidson‑Dixon, 170 N.E.3d 557 (2021) (reiterates that a single punch is nondeadly force)