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State v. Wilson
2012 Ohio 1952
Ohio Ct. App.
2012
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Background

  • Samuel Wilson operated a home auto repair business in Cleveland with several workers, including Jason Andrews.
  • Andrews previously worked for a cable company and sometimes unlawfully reconnected services for a fee, a practice Wilson denied.
  • Wilson suspected Andrews (and possibly Huggins) of stealing tools worth about $4,500 and withheld about $100 from Andrews for work performed.
  • Andrews allegedly threatened to “bring the fire” if not paid, a message Wilson attributed to Andrews via Huggins.
  • On April 6, 2011, Andrews entered or attempted to enter Wilson’s home; Wilson fired his gun after perceiving a threat.
  • Two shots were fired (five minutes apart); Andrews was wounded in the stomach and head, Wright was outside, and police later found Andrews’s phone in Wilson’s yard.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the evidence supports attempted murder beyond a reasonable doubt State argues evidence proves intent to kill Wilson contends self-defense or insufficient proof of intent to kill Evidence supports attempted murder; sufficient to sustain conviction
Whether convictions were against the manifest weight given self-defense State asserts Castle Doctrine rebuttal of self-defense Wilson asserts self-defense preponderates Castle Doctrine applies; state rebutted presumption; weight not against verdict

Key Cases Cited

  • State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency standard for criminal review)
  • State v. Dykas, 2010-Ohio-359 (8th Dist. 2010) (self-defense weight standard for review)
  • State v. Kozlosky, 2011-Ohio-4814 (8th Dist. 2011) (elements of self-defense and Castle Doctrine considerations)
  • State v. Johnson, 2010-Ohio-145 (8th Dist. 2010) (Castle Doctrine presumption in home expulsion/defense)
  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (weight-of-the-evidence standard for reversing a verdict)
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Case Details

Case Name: State v. Wilson
Court Name: Ohio Court of Appeals
Date Published: May 3, 2012
Citation: 2012 Ohio 1952
Docket Number: 97350
Court Abbreviation: Ohio Ct. App.