State v. Brown

Citations

• 2025 Ohio 2351

Syllabus

MANIFEST WEIGHT – MURDER – SELF-DEFENSE – SENTENCING – SPECIFICATIONS – R.C. 2929.14(B)(1)(g): Defendant's conviction for murder was not contrary to the manifest weight of the evidence because the State, in disproving defendant's self-defense defense, demonstrated both that defendant was responsible for creating the conflict and that defendant lacked a bona fide belief that he faced imminent death or great bodily harm. The trial court did not err in failing to merge the firearm specifications for purposes of sentencing and ordering them to be served consecutively because R.C. 2929.14(B)(1)(g) requires that certain offenders receive prison terms for multiple specifications, and imposing separate prison terms for multiple firearm specifications is required even when the criminal offenses to which those firearm specifications are attached have been merged as allied offenses. See State v. Bollar, 2022-Ohio-4370, ¶ 1.