State v. White

Citations

• 2019 Ohio 4312

Syllabus

Defendant appeals conviction for murder where defendant admitted stabbing victim in neck with knife. Defendant claimed self-defense. Defendant failed to follow procedures for requesting disqualification of trial judge court of appeals lacked authority to review. Defendant not denied fair trial where jury instructions complicated by self-defense and voluntary manslaughter instructions. Statements of law were accurate, and no evidence jury was confused. Admission of defendant's recorded jailhouse telephone call to family member did not violate Confrontation Clause not testimonial in nature. Call did not violate hearsay rule defendant's statements were admissible as admissions of a party-opponent, other party's statements admissible to provide context to defendant's admissible statements. Court did not abuse discretion in admitting bloody crime scene photographs where each photograph distinct and helpful to the jury in assessing the state and defendant's claims concerning what occurred at the crime scene. Simply because photographs were gruesome would not indicate that jurors could not fairly decide the case. Manifest weight of evidence supported defendant's conviction for murder. Defendant did not prove self-defense where evidence supported conclusion that the defendant unreasonably elevated the confrontation to a potential deadly engagement and where defendant failed to make reasonable effort to escape danger. The evidence would not have supported a voluntary manslaughter conviction where the defendant claimed he attacked the victim out of fear, and only became enraged after the victim had been stabbed several times in the neck.