State v. McDonald

Citations

• 2023 Ohio 1987

Syllabus

SELF-DEFENSE – R.C. 2901.05 – MANIFEST WEIGHT – SENTENCING – REAGAN TOKES LAW: Where the evidence established that defendant was lawfully in the apartment where the victim was shot, and that the victim had unlawfully and without privilege to do so entered the apartment, defendant was entitled to a presumption that he acted in self-defense. Where the state proved beyond a reasonable doubt that defendant did not have a bona fide belief that he was in imminent danger of death or great bodily harm, defendant's conviction for voluntary manslaughter was not against the manifest weight of the evidence. The Reagan Tokes Law does not violate the separation-of-powers doctrine, substantive due process, procedural due process, or the Equal Protection Clause.