State v. Baker, 2022 Ohio 1853

Victim Jayla Wyatt was found shot multiple times in a Zanesville apartment on April 27, 2021; six 9mm shell casings were recovered and no weapon at scene.
Witnesses and surveillance placed a robin-egg-blue two-door car and a slim female leaving the scene; phone data, photos, and a call log tied the 614 number to Tristaney (Kristin) Baker.
Co-defendant/bystander's statements and Baker's boyfriend Devin McKnelly implicated Baker: McKnelly admitted obtaining and transporting the firearm; a witness reported Baker bragging she shot the victim multiple times.
Baker was indicted on aggravated murder (two counts with firearm specifications), aggravated burglary, tampering with evidence, and possession of criminal tools; she pleaded guilty to all counts.
Trial court merged murder counts for sentencing and imposed life without parole plus six additional years (concurrent terms with consecutive firearm specifications); Baker appealed.
Appellate issues: (1) ineffective assistance of counsel for not seeking a competency evaluation and not obtaining a psychological report to support mitigation; (2) challenge to constitutionality of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Baker received ineffective assistance because counsel did not request a competency evaluation	State: Record lacks indicia of incompetence; presumption of competence stands	Baker: Counsel should have sought competency evaluation based on mental-health indicators and behaviors	Court: No prejudice shown; record lacked sufficient indicia of incompetence; counsel not ineffective
Whether counsel was ineffective for failing to obtain a psychological report supporting mitigation	State: Counsel presented extensive mitigating evidence and avoided death penalty	Baker: A psychological evaluation would have bolstered mitigation and possibly affected sentencing	Court: Counsel reasonably presented mitigation; plea avoided death; no deficient performance shown
Whether Baker's sentence is unconstitutional / contrary to law	State: Sentencing court considered statutory purposes/factors and stayed within statutory ranges	Baker: Sentence excessive/unconstitutional (argued)	Court: Sentences were within statutory range, trial court considered §2929.11/§2929.12; not clearly and convincingly contrary to law; affirmed

Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel)
Lockhart v. Fretwell, 506 U.S. 364 (prejudice inquiry under Strickland)
Dusky v. United States, 362 U.S. 402 (competency to stand trial standard)
State v. Bradley, 42 Ohio St.3d 136 (ineffective-assistance analysis in Ohio)
State v. Roberts, 137 Ohio St.3d 230 (definition of competency cited from Dusky)
State v. Bock, 28 Ohio St.3d 108 (insufficient indicia of incompetence standard)
State v. Lawson, 165 Ohio St.3d 445 (when counsel need not request competency evaluation)
State v. Thomas, 97 Ohio St.3d 309 (same context regarding competency requests)
State v. Bonnell, 140 Ohio St.3d 209 (appellate review limits for sentencing under R.C. §2953.08)
State v. Marcum, 146 Ohio St.3d 516 (sentencing review standard)
State v. Jones, 169 N.E.3d 649 (appellate court cannot reweigh sentencing factors)