State v. Messenger

Citations

• 171 Ohio St. 3d 227
• 216 N.E.3d 653
• 2022 Ohio 4562

Syllabus

Criminal law—R.C. 2901.05—Affirmative defenses—Self-defense—Burden of production and burden of persuasion—Defendant has burden of production regarding self-defense claim and must produce legally sufficient evidence that defendant's use of force was in self-defense—State then has burden of persuasion to disprove self-defense claim beyond a reasonable doubt—On appeal, sufficiency-of-the-evidence standard of review applies to defendant's burden of production and manifest-weight standard of review applies to state's burden of persuasion—Court of appeals' judgment affirmed.