State v. Pitts

Citations

• 163 N.E.3d 1169
• 2020 Ohio 5494

Syllabus

JURY INSTRUCTION – DEFENSE OF ANOTHER – SELF-DEFENSE – RETROACTIVITY – R.C. 2901.05: Where defendant presented an affirmative defense of defense of another at his jury trial, the trial court erred in failing to instruct the jury in accordance with the burden-shifting provisions of 2017 Am.Sub.H.B. No. 228 because H.B. 228 applies prospectively to trials and defendant's trial occurred after the effective date of H.B. 228.