State v. Wilson, 2022 Ohio 3801

In October 2020 multiple shots were fired at the Hawaiian Terrace complex; Sherron Peoples ran into his apartment bleeding from the hand and bullets struck the living-room window.
Jeree Wilson went upstairs, retrieved a 9 mm handgun she kept at home, stepped outside, and fired multiple rounds down the driveway toward the general area she believed the shots came from.
A bullet was later found lodged in the front door of the residence across from Wilson’s apartment; police concluded the bullet came from Wilson’s gun.
Wilson was indicted for one count of improperly discharging a firearm at or into a habitation (R.C. 2923.161(A)(1)); at trial she asserted self-defense/defense of others.
The jury was instructed on self-defense and defense of others but rejected Wilson’s claim and convicted her; she appealed, arguing the verdict was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wilson’s conviction was against the manifest weight because the jury rejected her self-defense claim	State: Wilson lacked an objectively reasonable belief of imminent danger because she did not see the shooter or know his location; shooting had ceased and she fired indiscriminately into residences, so force was not her only means of escape	Wilson: After Peoples returned wounded and bullets hit her home, she reasonably believed she and her family faced imminent great bodily harm and fired to protect them	Affirmed. The court found the state disproved the honesty/objective-reasonableness element of self-defense beyond a reasonable doubt given the time gap, lack of knowledge of the shooter, and indiscriminate firing

State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (elements of self-defense for use of deadly force)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest-weight review as the "thirteenth juror" standard)
State v. Martin, 20 Ohio App.3d 172 (1st Dist. 1983) (manifest-miscarriage-of-justice reversal standard)
State v. Thomas, 77 Ohio St.3d 323 (Ohio 1997) (requires subjective honest belief if objective reasonableness met)