The Supreme Court of Ohio is set to deliberate on whether a jury's determination from a man's initial murder trial should be upheld in a retrial. The case involves Dujuan Wiley, who was convicted of felony murder and voluntary manslaughter following an incident in September 2018. During this event, Wiley claimed he acted in self-defense after being attacked by three men, one of whom was Antoine Reese. Wiley admitted to shooting Reese as the latter attempted to flee.
Wiley was found guilty of both felony murder and voluntary manslaughter. The jury determined that he acted under "sudden passion or rage," influenced by serious provocation from the victim. This verdict led Wiley to appeal his conviction, arguing it is inconsistent with the charges against him.
The Eighth District Court of Appeals ordered a new trial, focusing on felonious assault, felony murder, and voluntary manslaughter charges. Wiley has requested the Supreme Court dismiss the more severe charges based on double jeopardy principles and collateral estoppel—arguing that since he was found to have acted with passion or rage initially, this finding should carry over into his retrial.
At an off-site session at Jackson Middle School in Jackson County, arguments will be heard regarding whether the first trial's findings must influence subsequent proceedings. The Cuyahoga County Prosecutor’s Office maintains that the second jury is not bound by previous decisions and can consider all charges anew.
Wiley's case brings into question jury instructions during his initial trial. The prosecutor had two theories: Wiley committed felony murder through felonious assault or voluntary manslaughter due to sudden provocation. However, instructions for considering provocation were only provided for voluntary manslaughter but not for other charges.
After his conviction on all counts, discussions arose about whether Wiley could be guilty of felonious assault if acting under passion or rage—a scenario which would reduce the charge severity potentially affecting the felony murder conviction.
As oral arguments approach at Jackson Middle School on April 24th, interest grows around how double jeopardy clauses might impact this case. Arguments will be available online through official channels.
The court will also hear two other cases during its session: State v. Wogenstahl concerning jurisdictional issues related to state law; and State v. Hickman involving mental health restrictions following a long-term commitment after a not-guilty-by-reason-of-insanity verdict.