State v. Wright
2017 Ohio 1225
| Ohio Ct. App. | 2017Background
- In October 2013, cellmates Cedric Wright and Michael Dodson fought in their shared cell at Toledo Correctional Institution; Dodson was beaten, transported to a hospital, and died the next day of blunt head and neck injuries ruled a homicide.
- Wright was indicted on purposeful murder (R.C. 2903.02(A)) and murder committed during a felony (R.C. 2903.02(B)). A jury acquitted on purposeful murder but convicted on the felony-murder count; Wright was sentenced to life with parole possible after 15 years.
- Surveillance video and officer testimony showed Wright on top of Dodson, repeatedly punching, choking, and slamming his head; Wright twice stopped and resumed the attack, shoved an officer who tried to intervene, and jammed the door with a battery to impede entry.
- Wright urged a self-defense theory at trial and requested a jury instruction; the trial court gave a self-defense instruction but did not instruct using the common-law/codified "castle doctrine" formulation regarding no duty to retreat.
- On appeal Wright raised three issues: (1) plain error in the self-defense instruction (duty to retreat/castle doctrine), (2) ineffective assistance for counsel’s failure to object to that instruction, and (3) that the conviction was against the manifest weight of the evidence.
- The Sixth District affirmed, finding (a) any omission of a castle-doctrine instruction was not plain error because retreat was possible and Wright actively prevented intervention and continued the assault, (b) no ineffective assistance because there was no reasonable probability a proper instruction would have changed the outcome, and (c) the verdict was not against the manifest weight of the evidence.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Wright) | Held |
|---|---|---|---|
| Jury instruction on self-defense duty to retreat / castle doctrine | Trial court’s self-defense instruction was adequate; no reversible error | Omission of castle doctrine/no-duty-to-retreat language was plain error and prejudicial | Court: No plain error — retreat was possible, officers intervened, Wright prevented help and continued assault; outcome would not clearly differ |
| Ineffective assistance for failing to object to jury charge | Counsel’s conduct did not prejudice defendant; evidence doomed self-defense claim | Counsel ineffective for not objecting; lower Strickland burden shows reasonable probability of different outcome | Court: No ineffective assistance — no reasonable probability the verdict would change given undisputed facts showing excess force |
| Manifest weight of the evidence | Verdict supported by overwhelming evidence, eyewitnesses, and video | Conviction contrary to weight because evidence corroborates Wright’s claim that Dodson attacked first | Court: Not against the manifest weight — jury not required to credit Wright; evidence supports conviction |
| Application of precedent (Cassano/Thomas) to duty-to-retreat issue | Cassano/Thomas permit consideration of castle doctrine but facts control; no reversal here | Cassano requires no-duty-to-retreat instruction for cell/home situations like this | Court: Distinguished Cassano — cell was not locked, retreat was available, and Wright prevented intervention; Cassano not controlling here |
Key Cases Cited
- State v. Cassano, 96 Ohio St.3d 94 (trial court should not instruct duty to retreat where retreat impossible in locked cell; but no prejudice found)
- State v. Thomas, 77 Ohio St.3d 323 (discusses castle doctrine and self-defense context)
- State v. Jackson, 22 Ohio St.3d 281 (elements required to establish self-defense)
- State v. Hill, 92 Ohio St.3d 191 (plain-error review in criminal cases)
- Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel)
- State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight review standard)