State v. Pursley

2025 Ohio 530
CourtOhio Court of Appeals
DecidedFebruary 19, 2025
Docket30853
StatusPublished
Cited by1 cases

This text of 2025 Ohio 530 (State v. Pursley) 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. Pursley, 2025 Ohio 530 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Pursley, 2025-Ohio-530.]

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

STATE OF OHIO C.A. No. 30853

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE ERIC PURSLEY COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellant CASE No. CR-2022-11-3952

DECISION AND JOURNAL ENTRY

Dated: February 19, 2025

CARR, Judge.

{¶1} Defendant-Appellant Eric Pursley appeals the decision of the Summit County Court

of Common Pleas. This Court affirms.

I.

{¶2} On October 5, 2022, Pursley shot and killed his landlord during a dispute. In

November 2022, Pursley was charged with two counts of murder and two counts of felonious

assault. A firearm specification accompanied each count. The matter proceeded to a jury trial, at

which Pursley maintained that he acted in self-defense. During deliberations, after the jury

expressed some uncertainty about being able to reach a verdict, the trial court, without objection,

read the jury the Howard charge. See State v. Howard, 42 Ohio St.3d 18 (1989), paragraph two

of the syllabus. Thereafter, the jury found Pursley not guilty of one count of murder and guilty of

the remaining charges and specifications. The trial court sentenced Pursley accordingly. 2

{¶3} Pursley has appealed, raising three assignments of error, which will be addressed

out of sequence to facilitate our review.

II.

ASSIGNMENT OF ERROR I

APPELLANT’S CONVICTIONS WERE BASED ON INSUFFICIENT EVIDENCE AND AGAINST THE MANIFEST WEIGHT.

{¶4} Pursley argues in his first assignment of error that his convictions were based on

insufficient evidence and were against the manifest weight of the evidence. Specifically, he asserts

that the evidence supports that he acted in self-defense.

Sufficiency

{¶5} With respect to Pursley’s sufficiency challenge, we conclude it is misplaced in light

of his focus on self-defense. “Self-defense remains an affirmative defense in Ohio, and an

affirmative defense is not an element of a crime[.]” State v. Messenger, 2022-Ohio-4562, ¶ 24.

“[A] defendant charged with an offense involving the use of force has the burden of producing

legally sufficient evidence that the defendant’s use of force was in self-defense.” Id. at ¶ 25.

Accordingly, a trial court judge who has instructed a jury on self-defense has determined the

defendant put forth sufficient evidence of self-defense. Id. at ¶ 26. Meanwhile, a finding of guilt

means that, in the eyes of the jury, the State met its burden of persuasion that the defendant was

not acting in self-defense. Id. “[T]he sufficiency-of-the-evidence standard of review applies to

[the defendant’s] burden of production and a manifest-weight-of-the-evidence standard of review

applies to the state’s burden of persuasion.” Id. Given that Pursley’s argument is focused on self-

defense, a challenge to the sufficiency of the evidence is not appropriate. See id. at ¶ 26-27; see

also State v. Susanek, 2024-Ohio-5298, ¶ 22 (9th Dist.). 3

Manifest Weight

In determining whether a criminal conviction is against the manifest weight of the evidence, an appellate court must review the entire record, weigh the evidence and all reasonable inferences, consider the credibility of witnesses and determine whether, in resolving conflicts in the evidence, the trier of fact clearly lost its way and created such a manifest miscarriage of justice that the conviction must be reversed and a new trial ordered.

State v. Otten, 33 Ohio App.3d 339, 340 (9th Dist. 1986). An appellate court should exercise the

power to reverse a judgment as against the manifest weight of the evidence only in exceptional

cases. Id. “[W]e are mindful that the jury is free to believe all, part, or none of the testimony of

each witness. This Court will not overturn a conviction on a manifest weight challenge only

because the jury found the testimony of certain witnesses to be credible.” (Internal quotations and

citations omitted.) State v. Becton, 2023-Ohio-4841, ¶ 38 (9th Dist.)

{¶6} Pursley was found guilty of murder in violation of R.C. 2903.02(B), which states,

“[n]o person shall cause the death of another as a proximate result of the offender’s committing or

attempting to commit an offense of violence that is a felony of the first or second degree and that

is not a violation of [R.C. 2903.03] or [R.C. 2903.04].” The indictment specified that the pertinent

felony was felonious assault pursuant to R.C. 2903.11. In addition, Pursley was found guilty of

two counts of felonious assault, one in violation of R.C. 2903.11(A)(1), and the other in violation

of R.C. 2903.11(A)(2). R.C. 2903.11(A) provides that “[n]o person shall knowingly do either of

the following: (1) Cause serious physical harm to another or to another’s unborn; (2) Cause or

attempt to cause physical harm to another or to another’s unborn by means of a deadly weapon or

dangerous ordnance.” A firearm specification also accompanied each count. See R.C.

2941.145(A).

{¶7} R.C. 2901.05(B) provides: 4

(1) A person is allowed to act in self-defense, defense of another, or defense of that person’s residence. If, at the trial of a person who is accused of an offense that involved the person’s use of force against another, there is evidence presented that tends to support that the accused person used the force in self-defense, defense of another, or defense of that person’s residence, the prosecution must prove beyond a reasonable doubt that the accused person did not use the force in self-defense, defense of another, or defense of that person’s residence, as the case may be.

(2) Subject to division (B)(3) of this section, a person is presumed to have acted in self-defense or defense of another when using defensive force that is intended or likely to cause death or great bodily harm to another if the person against whom the defensive force is used is in the process of unlawfully and without privilege to do so entering, or has unlawfully and without privilege to do so entered, the residence or vehicle occupied by the person using the defensive force.

(3) The presumption set forth in division (B)(2) of this section does not apply if either of the following is true:

(a) The person against whom the defensive force is used has a right to be in, or is a lawful resident of, the residence or vehicle.

(b) The person who uses the defensive force uses it while in a residence or vehicle and the person is unlawfully, and without privilege to be, in that residence or vehicle.

(4) The presumption set forth in division (B)(2) of this section is a rebuttable presumption and may be rebutted by a preponderance of the evidence, provided that the prosecution's burden of proof remains proof beyond a reasonable doubt as described in divisions (A) and (B)(1) of this section.

{¶8} A self-defense claim requires:

(1) that the defendant was not at fault in creating the situation giving rise to the affray; (2) that the defendant had a bona fide belief that he [or she] was in imminent danger of death or great bodily harm and that his [or her] only means of escape from such danger was in the use of such force; and (3) that the defendant did not violate any duty to retreat or avoid the danger.

Messenger, 2022-Ohio-4562, at ¶ 14, quoting State v. Barnes, 94 Ohio St.3d 21, 24 (2002). “All

three of these elements must be present to establish self-defense. To carry its burden of persuasion,

the State need only disprove one of the foregoing elements beyond a reasonable doubt.” (Internal

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Bluebook (online)
2025 Ohio 530, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-pursley-ohioctapp-2025.