State v. Adkins
2020 Ohio 6799
Ohio Ct. App.2020Background
- On September 3, 2017 Clois‑Ray H. Adkins struck Robert L. Smith II in the head with a tree branch, causing Smith’s death. Adkins was indicted on two murder counts and two felonious‑assault counts.
- Defense timely raised competency and insanity concerns; the court ordered multiple competency and sanity evaluations and held a competency hearing where the parties stipulated to two expert reports (Dr. Stinson for defense; Dr. Marciani for the State).
- The trial court found Adkins competent to stand trial and declined to apply the December 2018 amendments to Ohio’s self‑defense statute (H.B. 228) retroactively, because the offenses occurred before the amendments’ effective date.
- A jury convicted Adkins on all four counts in June 2019; the court merged counts and sentenced him to 15 years to life on the murder conviction.
- Adkins appealed, raising three assignments of error: (1) trial court violated due process by requiring him to stand trial while incompetent; (2) jury instruction improperly placed the burden on Adkins to prove self‑defense (challenging nonretroactive application of amended R.C. 2901.05); and (3) convictions were against the manifest weight of the evidence because he acted in self‑defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competency to stand trial — did court err in finding Adkins competent? | State: competency hearing testimony and reports supported finding Adkins could consult with counsel and assist in his defense. | Adkins: trial court lacked reliable, credible evidence and abused discretion by ruling him competent. | Court: No abuse of discretion; record contains reliable, credible evidence and trial court reasonably credited State expert. |
| Jury instruction/burden on self‑defense — should amended R.C. 2901.05 (H.B. 228) apply? | State: 2019 amendments are not retroactive; pre‑amendment law (defendant bears burden to prove self‑defense by preponderance) governs because offense occurred in 2017. | Adkins: trial after amendments effective date entitled him to burden‑shifting instruction requiring prosecution to disprove self‑defense beyond a reasonable doubt. | Court: H.B. 228 is not expressly retroactive; under R.C. 1.48 and Ohio precedent defendant is tried under law in effect when offense occurred. No error. |
| Manifest weight — did evidence show Adkins acted in self‑defense? | State: evidence (witness testimony and cellphone video) showed Adkins armed himself with a branch, confronted Smith, and struck him; defendant created the situation. | Adkins: he was pursued and acted to defend himself; jury should have found self‑defense. | Court: Weight favors State; Adkins was at fault for creating the affray (armed and pacing in the neighborhood), so self‑defense not proven by preponderance. Conviction affirmed. |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) (establishes federal competency standard: ability to consult with counsel and factual/rational understanding of proceedings)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (conviction of legally incompetent defendant violates due process)
- Pate v. Robinson, 383 U.S. 375 (U.S. 1966) (due process requires competency determination when evidence raises substantial doubt)
- Landgraf v. USI Film Prods., 511 U.S. 244 (U.S. 1994) (presumption against retroactive legislation; fairness and settled expectations inform retroactivity analysis)
- Kiser v. Coleman, 28 Ohio St.3d 259 (Ohio 1986) (statutes not applied retroactively absent clear legislative intent)
- State v. Clark, 71 Ohio St.3d 466 (Ohio 1994) (standard of review and deference for trial court competency determinations)
- State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishes sufficiency from manifest‑weight review)