Martin v. Ohio
United States Supreme Court
480 U.S. 228 (1987)
During an argument, the husband of Earline Martin (defendant) hit her in the head. According to Martin, she picked up her husband’s gun to get rid of it. When the husband saw something in Martin’s hand, he lunged at her. Martin lost control and fired the gun at her husband, killing him. Martin was charged with aggravated murder, which Ohio law defined as purposely causing another’s death with prior calculation and design. Martin pleaded 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 Martin’s contention that placing the burden on Martin 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 Martin 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 Martin 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 Martin, and Martin appealed.
Rule of Law
Holding and Reasoning (White, J.)
Dissent (Powell, J.)
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