State v. Rose

Summary

The Ninth District Court of Appeals of Ohio affirmed Raven Nichole Rose’s conviction for felonious assault. The court rejected her manifest-weight challenge, concluding that the jury did not clearly lose its way in rejecting her self-defense claim. The opinion discusses the elements of self-defense and the respective burdens of production and persuasion.

Holdings

1. A conviction may be reversed on manifest-weight grounds only when, after reviewing the entire record and weighing the evidence and witness credibility, the appellate court concludes that the trier of fact clearly lost its way and created a manifest miscarriage of justice; reversal is reserved for the exceptional case in which the evidence weighs heavily against the conviction.
2. When a defendant produces legally sufficient evidence of self-defense, the State bears the burden of persuasion to prove beyond a reasonable doubt that the defendant did not use force in self-defense, and the State's failure to carry that burden is subject to manifest-weight review on appeal.

Questions Presented

1. Whether Rose's felonious-assault conviction was against the manifest weight of the evidence because the jury rejected her claim of self-defense.

Disposition

affirmed