Martin v. Ohio

Facts

During an argument, Earline Martin’s (Defendant) husband hit her in the head. According to Defendant, she picked up her husband’s gun to get rid of it. When the husband saw something in Defendant’s hand, he lunged at her. Defendant lost control and fired the gun at her husband, killing him. Defendant was charged with aggravated murder, which was defined under Ohio law as purposely causing another’s death with prior calculation and design. Defendant pled self-defense, an affirmative defense under Ohio law, which the defendant has the burden of proving by a preponderance of the evidence. The judge rejected Defendant’s contention that placing the burden on Defendant to prove self-defense violated her right to due process, and the judge instructed the jury that a conviction required a finding that: 1) the state had proved each element of aggravated murder beyond a reasonable doubt and 2) none of the self-defense evidence had raised a reasonable doubt that Defendant purposely killed her husband with a prior design. The jury was also instructed that an acquittal required a finding by a preponderance of the evidence that Defendant acted in self-defense and: 1) did not start the argument with her husband; 2) honestly believed that she was an imminent danger; and 3) satisfied any duty to retreat. The jury convicted Defendant and both the Ohio Court of Appeals and Supreme Court affirmed. Defendant appealed.