Martin v. Ohio

Earline Martin (defendant) shot and killed her husband during a physical altercation, claiming she picked up his gun to get rid of it and fired only after he lunged at her. Ohio charged her with aggravated murder (purposely causing death with prior calculation and design) and, as Ohio law required, placed on Martin the burden of proving her self-defense claim by a preponderance of the evidence. The jury was instructed that conviction required finding the state proved every element of aggravated murder beyond a reasonable doubt and that self-defense evidence hadn't raised a reasonable doubt about prior calculation, while acquittal required Martin to prove self-defense by a preponderance. The jury convicted Martin, and she appealed, arguing the burden allocation itself violated due process.