State v. Coates

Citations

• 2025 Ohio 5340

Syllabus

Murder; attempted murder; self-defense; castle doctrine; rebuttable presumption of self-defense; reasonable force; jury instructions; lesser-included offenses; expert testimony; post-traumatic stress disorder. Defendant's convictions for murder, attempted murder and felonious assault, all with firearm specifications, are affirmed. Defendant admitted to shooting and killing his roommate but argued that he did so in self-defense. The victim was coming home and attempting to enter the house through the front door, with her seven-month-old child in her arms, when the defendant fired 14 shots from an assault rifle through the closed door while he was inside the house. The defendant argued he acted in self-defense because he has post-traumatic stress disorder and he thought someone was trying to unlawfully enter the house. He failed to look at the doorbell camera video of the front door before firing his gun. The court did not err in instructing the jury regarding self-defense and the castle doctrine. The court did not err in not instructing the jury regarding lesser-included offenses, because the defendant acted knowingly and/or purposefully when he fired the assault rifle. The court did not err in allowing defendant's expert witness to testify about post-traumatic stress disorder but limiting what the expert said about the defendant's state of mind.