State v. McElroy

2023 Ohio 1609
CourtOhio Court of Appeals
DecidedMay 15, 2023
Docket22CA011846
StatusPublished
Cited by6 cases

This text of 2023 Ohio 1609 (State v. McElroy) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. McElroy, 2023 Ohio 1609 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. McElroy, 2023-Ohio-1609.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

STATE OF OHIO C.A. No. 22CA011846

Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE EBONI MCELROY COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellee CASE No. 20CR102466

DECISION AND JOURNAL ENTRY

Dated: May 15, 2023

STEVENSON, Judge.

{¶1} Plaintiff-Appellant, State of Ohio, appeals from the judgment of the Lorain County

Court of Common Pleas granting Defendant-Appellee, Eboni McElroy’s, Crim.R. 29(B) and (C)

motion for judgment of acquittal. Although the trial court erred in granting Ms. McElroy’s motion

for acquittal, for the following reasons we affirm the judgment of acquittal and remand for further

proceedings.

I

{¶2} On June 24, 2020, the Lorain County Grand Jury indicted Ms. McElroy on the

following charges: murder in violation of R.C. 2903.02(A), an unclassified felony (count one);

murder in violation of R.C. 2903.02(B) (count two), an unclassified felony; murder in violation of

R.C. 2903.02(B) (count three), an unclassified felony; felonious assault in violation of R.C.

2903.11(A)(1), a felony of the second degree (count four); felonious assault in violation of R.C. 2

2903.11(A)(2) (count five), a felony of the second degree; and tampering with evidence in

violation of R.C. 2921.12(A)(1) (count six), a felony of the third degree.

{¶3} The case proceeded to a jury trial. At the close of the State’s case, Ms. McElroy

moved for a judgment of acquittal pursuant to Crim.R. 29(A), which the trial court denied. Ms.

McElroy proceeded with her case, after which she renewed her motion for a judgment of acquittal

under Crim.R. 29(A). The trial court reserved its decision on the renewed motion and the matter

proceeded to closing arguments.

{¶4} After deliberations, the jury found Ms. McElroy guilty on counts three, five, and

six, and specifically found that she did not act in self-defense or in the defense of her residence in

the death of the victim, I.B. The jury issued not guilty verdicts on counts one, two, and four.

{¶5} After the jury’s verdict, Ms. McElroy orally renewed her motion for a judgment of

acquittal. Arguments took place on the record and the trial court reserved its decision. Fourteen

days later, Ms. McElroy also filed a written motion for judgment of acquittal under Crim.R. 29(C),

stating in support that despite the jury verdict, the State failed to present sufficient evidence to

disprove the affirmative defense of self-defense. The State opposed the motion.

{¶6} The trial court granted Ms. McElroy’s Crim.R. 29 motion as to counts three and

five. The trial court acknowledged that under the H.B. 228 amendments to R.C. 2901.05 that went

into effect on March 28, 2019, the burden of proof shifted to the State to disprove one of the

elements of self-defense once Ms. McElroy presented evidence supporting that she acted in self-

defense. In its analysis, the trial court stated that the issue before it was Ms. McElroy’s claim that

the State did not present sufficient evidence to rebut her claim of self-defense. The trial court

ultimately concluded that “in reviewing the sufficiency of the evidence in a light most favorable 3

to the State, this Court finds that no rational trier of fact could have found that the State disproved,

beyond a reasonable doubt, that Defendant acted in self-defense.”

{¶7} As Ms. McElroy did not address count six in her motion for acquittal, the trial court

denied her motion on that count. The trial court vacated Ms. McElroy’s judgment of conviction as

to counts three and five and denied her motion for a new trial. The judgment of conviction on

count six remains.

{¶8} The State appealed pursuant to App.R. 5(C) (motion by prosecution for leave to

appeal). This Court provisionally granted the State’s motion for leave to appeal the substantive

law ruling at issue to the extent it is not tied to the specific facts of the case, referencing State ex

rel. Ramirez-Ortiz v. Twelfth Dist. Court of Appeals, 151 Ohio St.3d 46, 2017-Ohio-7816, ¶ 10

(“the state can appeal a discrete legal issue when the question is capable of repetition yet evading

review”).

{¶9} The State raises one assignment of error for our review.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ERRED BY GRANTING APPELLEE EBONI MCELROY’S POST-VERDICT CRIM.R. 29 MOTION BECAUSE IT IMPROPERLY APPLIED A SUFFICIENCY-OF-THE EVIDENCE ANALYSIS WHEN CONSIDERING MCELROY’S SELF-DEFENSE ARGUMENTS.

{¶10} In its single assignment of error, the State argues that the absence of self-defense is

not an essential element of murder and felonious assault, and therefore, the trial court’s application

of a sufficiency-of-the-evidence analysis to Ms. McElroy’s Crim.R. 29 motion for acquittal was

contrary to law.

{¶11} On December 21, 2022, the Supreme Court of Ohio issued its decision in State v.

Messenger, Slip Opinion No. 2022-Ohio-4562, which addressed whether the State’s rebuttal of a 4

defendant’s claim of self-defense is now subject to review under the sufficiency-of-the evidence

standard. Id. at ¶ 1. The Supreme Court held that it was not, stating:

[t]he state’s new burden of disproving the defendant’s self-defense claim beyond a reasonable doubt is subject to a manifest-weight review on appeal, and the [appellate court] correctly declined to review the state’s rebuttal of self-defense for sufficiency of the evidence.

Id. at ¶ 27.

{¶12} In its decision, the Messenger Court affirmed that:

The change to the state’s burden of persuasion regarding self-defense in R.C. 2901.05(B)(1) did not change the elements of [the defendant’s] charged offenses * * *. [The] statutory requirement that the state must disprove an affirmative defense beyond a reasonable doubt does not in itself cause the affirmative defense to become an element of the offense.

(Emphasis added.) Id. at ¶ 24.

{¶13} The Messenger Court further noted that “[w]e have already determined that the

amendment to R.C. 2901.05(B)(1) was procedural, not substantive, in nature. State v. Brooks,

____ Ohio St.3d ____, 2022-Ohio-2478, at ¶ 15-16. The amendment * * * did not make

substantive changes to the elements of any offenses.” Id. at ¶ 22.

{¶14} Accordingly, based on the authority of Messenger, the State’s assignment of error

has merit. The trial court’s decision to grant Ms. McElroy’s motion for acquittal on counts three

and five was erroneous and contrary to law. However, even though the trial court erred, principles

of double-jeopardy bar Ms. McElroy’s retrial on those charges. State v. Sanabria, 11th Dist. No.

2018-A-0076, 2019-Ohio-2869, ¶ 19, citing State v. Keeton, 18 Ohio St.3d 379, 380-81 (1985) and

State v. Bistricky, 51 Ohio St.3d 157 (1990), syllabus (“[a] court of appeals has discretionary

authority pursuant to R.C. 2945.67(A) to review substantive law rulings made in a criminal case

which result in a judgment of acquittal so long as the judgment itself is not appealed”); State v. 5

Bickel, 178 Ohio App. 3d 535, 2008-Ohio-5747, ¶ 10. Therefore, the judgment of the trial court is

affirmed. Accord Sanabria at ¶19.

{¶15} Because the trial court granted Ms. McElroy an acquittal solely on counts three and

five, leaving count six remaining for adjudication, we remand this case to the trial court for further

proceedings consistent with this opinion.

III

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Bluebook (online)
2023 Ohio 1609, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mcelroy-ohioctapp-2023.