State v. Ireland
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The Supreme Court reversed the judgment of the Court of Appeals reversing Defendant’s conviction after ruling that Defendant’s blackout defense was not an affirmative defense that must be proven by a preponderance of the evidence, holding that blackout is an affirmative defense pursuant to Ohio Rev. Code 2901.05(D)(1)(b).
A jury found Defendant guilty of felonious assault. On appeal, Defendant argued that the trial court committed structural error by instructing the jury that blackout is an affirmative defense. The Court of Appeals agreed and reversed Defendant’s conviction. The Supreme Court reversed, holding (1) Defendant’s blackout defense was an affirmative defense that would allow the defendant to avoid liability even if the state produced sufficient evidence to support a conviction; (2) the requirement that the state prove that the defendant acted voluntarily is not an additional element or burden on the state; and (3) the trial court properly instructed the jury that the state had the burden of proving each element of the offense beyond a reasonable doubt, and the trial court did not shift to Defendant the state’s burden to prove an essential element of the offense charged.
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