State v. Pitts

2025 Ohio 2030
Procedural entryThis page is a short order in State v. Pitts. Read the opinion of the Court — 201 N.E.3d 983
Ohio Court of Appeals·Decided June 6, 2025·No. L-24-1050·Published

Opinion

[Cite as State v. Pitts, 2025-Ohio-2030.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State of Ohio Court of Appeals No. L-24-1050

Appellee Trial Court No. CR0202202607

v.

Andre Pitts DECISION AND JUDGMENT

Appellant Decided: June 6, 2025

***** Julia R. Bates and Brenda J. Majdalani, for appellee.

Laurel Kendall, for appellant. *****

OSOWIK, J.

{¶ 1} This is an appeal of a February 8, 2024 judgment of the Lucas County Court

of Common Pleas, convicting appellant, following a jury trial, on one count of felonious

assault, in violation of R.C. 2903.11, a felony of the second degree. Appellant was

sentenced to an indefinite term of incarceration, ranging from a minimum term of seven

years to a maximum term of ten and one-half years. For the reasons set forth below, this

court affirms the judgment of the trial court. {¶ 2} Appellant, Andre Pitts, sets forth the following five assignments of error:

I. The State of Ohio did not prove by a preponderance of the evidence that appellant did not act in defense of others, such that his conviction for felonious assault was against the manifest weight of the evidence. II. In the alternative, appellant’s conviction for felonious assault was against the manifest weight of the evidence. III. The medical records here were improperly used for investigative purposes, arguably in violation of Evid.R. 803(4). IV. The trial court abused its discretion when it allowed a detective to offer an arguably professional medical opinion concerning the victim, based on his review of medical records, and without corroboration by a medical professional. V. Appellant received ineffective assistance of counsel when counsel did not object to statements made by a detective concerning the victim’s medical condition, which were arguably investigative, and stipulated to the admission of medical records which were unredacted.

{¶ 3} The following undisputed facts are relevant to this appeal. This case arises

from an incident which occurred in the early morning hours of September 1, 2022,

following a night of heavy drinking by two groups of friends, previously unknown to one

another, who randomly crossed paths at a downtown Toledo bar.

{¶ 4} On August 31, 2022, Ho Nguyen and P.T., the victim in this case, were co-

workers at a Toledo-area nail salon. Following their shift at work that day, the friends

went out for drinks at the Cock N’ Bull, a downtown Toledo bar.

{¶ 5} That same evening, appellant, who worked at a downtown Toledo restaurant,

also went out for drinks at the Cock N’ Bull, likewise with a co-worker following their

shift at work. As the evening progressed, appellant noticed, and became increasingly

agitated by, the victim, who first caught appellant’s attention when attempting to give

him an unsolicited, unwanted fist bump. As appellant acknowledged during trial

2. testimony, “[The victim was] a typical drunk guy [who] tried to give me a fist bump and I

[didn’t] want a fist bump. This has been the same guy that been around the bar the whole

night[,] just everywhere.” Subsequent to the attempted fist bump, appellant stated to his

friends, “I’m going to fuck that dude up”, after which they attempted to calm him down.

{¶ 6} Later that night, Nguyen, went outside, laid down on a bench, and eventually

fell asleep on the bench, while waiting for the victim, who had remained inside the bar

until closing time. After the bar closed, the remaining patrons, including the victim,

appellant, and appellant’s friends, went outside and stood in the vicinity of the bench

where Nguyen had fallen asleep.

{¶ 7} In explaining the protocol when out drinking with the victim, Nguyen

testified, “[W]hen we go out and, you know, [and] we [are] both drunk, if [the victim]

was too drunk, I will wake him up like that [tapping him], or if me, [if] I am more drunk

than him, then he would come and tap me to wake me up * * * that’s normal, we tap each

other.”

{¶ 8} Appellant and his friends were standing outside smoking cigarettes after the

bar closed. The victim then came over, uninvited, and stood with appellant and his

friends, further aggravating appellant, who testified that the victim had, “Joined our party,

and just kinda stood there, for real.”

{¶ 9} Shortly thereafter, the victim walked over to the bench to awaken Nguyen,

which, as stated above, Nguyen testified was customary and was done, as needed, on a

reciprocal basis. Nguyen did not wake up, and was injured by the victim’s effort to rouse

him.

3. {¶ 10} As the victim attempted to awaken Nguyen, appellant erupted, darted

directly at the victim, and punched the victim squarely in the head with such a degree of

force that the victim fell onto the concrete pavement, with appellant falling on top of him.

The victim sustained a traumatic brain injury, and fragments of his teeth went into his

lungs. The victim’s injuries included subdural hematoma, herniation, subarachnoid

hemorrhage, skull fracture, acute respiratory failure, cerebral contusion, cerebral edema,

cerebral infarction, and hydrocephalus.

{¶ 11} A witness who was passing by during the incident observed appellant strike

the victim. In response, the witness called 9-1-1, and then attempted to assist the victim,

in response to which appellant threatened the witness. Emergency services and law

enforcement arrived on the scene several minutes later. The victim was transported for

emergency medical treatment, and law enforcement began investigating the incident. In

the interim, appellant and his friends had fled the scene. Appellant was subsequently

identified as the perpetrator.

{¶ 12} On September 20, 2022, appellant was indicted on one count of felonious

assault, in violation of R.C. 2903.11, a felony of the second degree. On September 18,

2023, a jury trial commenced. On September 19, 2023, a mistrial was declared due to

language translation issues regarding witness Nguyen. On February 5, 2024, after the

translation issue was rectified, a second jury trial commenced. On February 8, 2024,

appellant was found guilty and sentenced to an indefinite term of incarceration, ranging

from a minimum term of seven years to a maximum term of ten and one-half years. This

appeal ensued.

4. {¶ 13} In the first assignment of error, appellant argues that the trial court erred in

determining that the state disproved appellant’s self-defense claim beyond a reasonable

doubt, such that the felonious assault conviction was against the manifest weight of the

evidence. We do not concur.

{¶ 14} As this court held in State v. Bulger, 2023-Ohio-4004, ¶ 20 (6th Dist.),

To support a claim of self-defense involving the use of non-deadly force, the defendant must show that (1) he was not at fault in creating the situation giving rise to the affray; (2) he has reasonable grounds to believe or an honest belief that [another] was in imminent danger of bodily harm, and (3) he did not use more force than was reasonably necessary to defend against the danger of bodily harm. Greer, 6th Dist. Lucas No, L-22-1082, 2023- Ohio-103 at ¶ 33, quoting State v. Paskins, 200 N.E.3d 684, 2022-Ohio- 4024, ¶ 48 (5th Dist.).

{¶ 15} In conjunction, as this court held in State v. McClain, 2025-Ohio-577, ¶ 22

(6th Dist.),

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