## Facts

- A riot erupted at the Southern Ohio Correctional Facility in Lucasville, Ohio, on April 11, 1993; the relevant events occurred in the L-6 range of L-Block.
- L-6 was controlled by an electronic console that opened and closed cell and shower doors; the operator could see areas outside cell doors but not necessarily inside cells.
- Inmates took control of L-6 and restricted movement into and out of the range.
- A non-Muslim group of seven to ten inmates, described as a “death squad” led by Keith Lamar, entered L-6 intending to kill inmates believed to be informants.
- Timothy Grinnell operated the console as the group moved cell to cell.
- Two inmates, Darrell Depina and Bruce Harris, were beaten to death in L-6 cells by other inmates.
- The prosecution’s theory was complicity: by operating the console, Grinnell facilitated access to the victims and aided the aggravated murders.
- Grinnell did not personally deliver fatal blows; the dispute was whether he acted voluntarily or under threats.
- Defense witnesses testified Grinnell was threatened and ordered to work the console.
- State witnesses testified Grinnell exercised authority in L-6, including directing inmates to act as guards, ordering cleanup where beatings occurred, directing where people should be held, and refusing to open a particular cell door.

## Issues

1. Whether the trial court erred by refusing to instruct the jury that duress is a defense to aggravated murder (or negates the required mental state) under Ohio law.
2. Whether the trial court committed reversible error in challenged evidentiary rulings.
3. Whether other claimed trial errors (including alleged misconduct or instructional error) warranted reversal.

## Decision

- The court affirmed the aggravated-murder convictions and the concurrent life sentences with parole eligibility after 20 years.
- The court held duress is not a defense to aggravated murder involving the purposeful taking of life; therefore, the trial court properly refused a duress instruction on the aggravated-murder counts.
- The court rejected the remaining assignments of error, concluding the evidentiary rulings were within the trial court’s discretion and no other alleged errors required reversal.

## Legal Principles

- Under Ohio law, duress does not excuse or justify the purposeful killing of an innocent person and is not a defense to aggravated murder.
- A trial court need not instruct on a defense that is not legally available to the charged offense, even if evidence could support the factual claim of coercion.
- Appellate review of evidentiary admission and exclusion is for abuse of discretion; reversal requires a showing that the ruling was unreasonable, arbitrary, or unconscionable and affected substantial rights.
- Evidence that a defendant exercised discretion or authority may support a finding of voluntary participation and complicity rather than compelled conduct.

## Conclusion

The appellate court affirmed Grinnell’s aggravated-murder convictions arising from the Lucasville riot, holding that duress is not a defense to purposeful homicide in Ohio and that the trial court properly declined to instruct the jury on duress while committing no reversible trial or evidentiary error.


State v. Grinnell, 112 Ohio App. 3d 124, 678 N.E.2d 231 (Ohio Ct. App. 10th Dist. 1996)