State v. Parrish

Citations

• 2020 Ohio 4807

Syllabus

SELF-DEFENSE — BURDEN OF PROOF — PROCEDURE/RULES — HARMLESS ERROR: The trial court's failure to apply a new provision of the self-defense statute that requires the state to disprove a claim of self-defense was not harmless error in a prosecution for domestic violence where defendant went forward with evidence that tends to support that she used force in self-defense, a standard synonymous with the prior procedural burden. A remand for \further proceedings\ is appropriate when the trial court's error in a bench trial was the failure to apply the proper burden of proof.