State v. Snouffer

20 Ohio N.P. (n.s.) 65

This text of 20 Ohio N.P. (n.s.) 65 (State v. Snouffer) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Snouffer, 20 Ohio N.P. (n.s.) 65 (Ohio Super. Ct. 1917).

Opinions

Kinkead, J.

The indictment charged defendant with first degree murder by cutting the throat of the deceased with a razor. All the large vessels of the neck were severed; the wind pipe was cut; the carotid arteries were cut. 'The cut was a very deep one, extending clear back to the spinal column. The wound was necessarily fatal, and death resulted in a few moments.

All of the organs of the body were normal. The cause of death was a cut throat; secondary cause, hemorrhage.

The evidence clearly disclosed previous ill-will, malevolence, threats, and admissions that he had previously formed the design to take the life. It is not necessary to set them forth in detail: they are to bo found in the record. Acts of preparation and determination to kill are clear and distinct. The girl had refused his attentions and defendant had become enraged. On the occasion of the fatal visit to the house where deceased was employed, being unable to gain admission at the kitchen door, defendant went to another part of the house which was occupied by another family. When the door -was opened by a lady he insultingly and rudely inserted his foot in the doorway and prevented its being closed. He forced himself into [67]*67the house, and failing- to find his victim downstairs he forced his way upstairs by forcibly breaking- open the door leading from the dining room and ran upstairs. The door of the bed room where deceased had endeavored to secrete and protect herself was locked, but defendant forcibly broke it down. Deceased endeavored to run out and past defendant, but he caught her, and deliberately cut her throat in the presence of one of the ladies of the house, after having deliberately, quietly and politely asking her to step away.

The evidence clearly established antecedent threats, menaces, sullen malevolent spite and conduct, and admissions thereof by defendant.

It was a clear, typical case of first degree homicide.

On motion for new trial the contention is advanced that the court might have unwittingly produced some sort of influence on the jury by the charge given on the question of manslaughter and assaúlt and battery, and the decision of the court not to send to the jury forms of verdict for assault and battery.

Counsel for the defense contend that it has been the practice for many years to charge the jury upon all the elements of homicide including assault, assault and battery, and to send to the jury forms of verdict covering these lesser degrees of crime, in order that it might have an “untrammeled opinion as to their verdict without any suggestion from the court.” Counsel question whether the jury “were given absolute freedom by the court. ’ ’

As stated orally by the court the jury was not given untrammeled opinion as to their verdict and designedly not; under the charge the jury could only lawfully render a verdict for murder in the first or second degree,. although it might have rendered a verdict for manslaughter. But counsel suggest: Suppose the jury had rendered a verdict for a lesser degree of crime, could the court have set it aside? The judge must instruct the law applicable to the evidence. The answer is that the court is powerless to prevent such a miscarriage of justice.

A charge in criminal as well as in civil'cases must accurately present to the jury the questions presented by the indictmem and the evidence. Failure to correctly do this constitutes re versible error.

[68]*68But it is no legal sin to err against the state, and prosecutors seldom feel justified in prosecuting exceptions for the correction of an evil practice. Therefore, as long as trial courts travel along the path of least resistance, we are likely to move along in the old ruts of formalism.

The mind of the jury should be so quickened by the charge of the court that it may understand the law, and properly apply it to the ultimate facts deduced from the evidence. It should.be made to understand that the law of the instruction or rule of law stated therein has no relation to matter foreign to the evidence.

The charge or forms of verdict submitted should not make it possible for the jury to render a verdict which is not supported by any evidence, 'and thus contribute to a miscarriage of justice.

It has long been an unjustifiable practice in this state to instruct the jury as to the degrees of the homicide, including assault and battery, regardless of the fact whether the evidence sustains or warrants it.

The jury is thus given to understand that it is permitted to return any one of the forms of verdict from first, degree homicide to simple assault, regardless of the evidence, when there is no evidence tending to sustain any of the lesser offenses.

We have thus been slaves to custom and senseless formalism long enough. . Trial courts have pursued this- course rather by way of precaution, and without regard to law.

It is fundamental that an instruction to the jury must be founded on the claims of the parties made by the evidence. But no instruction should be given upon any phase of criminality embraced therein if there is no evidence tending to sustain it.

In this case there was no sudden quarrel, no heat of blood as in pure type of manslaughter; there was no provocation — no adequate provocation. The deceased on learning that defendant was at the house to see her ran away from him, locked herself in a bed room. There is no evidence of words or quarrel — nothing but cool deliberate determination to kill— carefully planned and executed.

[69]*69In order to precisely show how the questions were submitted to the jury, the material parts of the charge are here set forth:

“Murder in First Degree.
“Murder in the first degree consists in taking the life of another purposely and with deliberate and premeditated malice,
“Specific intent to kill with deliberate and premeditated malice are the essential elements of this degree of homicide.
“Intent, purpose to kill, deliberate and premeditated malice are manifestations'of the mind.
“While intent and malice are both descriptive of the mind, malice denotes a wicked purpose which characterizes the perpetration of a criminal act, and qualifies the intent and mind of the slayer.
“In first degree murder it is essential that the accused shall have formed the intent and purpose to kill, that he must have thought it over and deliberated upon it for some period of time and then to have carried it into execution.
“If the purpose to kill be the conception of but a moment, if it be thought over and considered by the accused for a short or long period of time, and is then carried out by the act of killing, it is done with deliberate and premeditated malice.
“Malice in First Degree.
“Malice in first degree murder must be express or actual as distinguished from implied malice, the characteristic of the second degree.

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Bluebook (online)
20 Ohio N.P. (n.s.) 65, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-snouffer-ohctcomplfrankl-1917.