State v. Cantrall, 2017 Ohio 7399

Defendant Matthew Cantrall was indicted on vandalism and obstructing official business charges after spray‑painting and damaging a rental property and confronting police in July 2015; he waived a jury trial and proceeded to a bench trial.
Two psychiatrists evaluated him: Dr. Lubna Grewal (court clinic) found competency and sanity; Dr. John Fabian (defense‑retained) reviewed St. Vincent Hospital records and concluded Cantrall was psychotic (schizoaffective/bipolar) and did not know the wrongfulness of his acts.
St. Vincent Hospital records and treating clinicians in mid‑July 2015 documented psychosis, mania, grandiosity, and medication noncompliance; the state conceded Cantrall had a severe mental disease or defect.
The trial court granted a Crim.R. 29 acquittal on one fourth‑degree vandalism count but convicted Cantrall of two fifth‑degree vandalism counts and one misdemeanor obstructing official business count; imposed concurrent community control sanctions.
At the insanity hearing, Dr. Grewal acknowledged psychotic features in the St. Vincent records (after reviewing Fabian’s report) but concluded Cantrall nonetheless knew the wrongfulness of his acts based on rational motives (e.g., "culture jamming," building a discrimination case), his behavior when police arrived (went inside, sought counsel, said "I plead the Fifth"), and her October 2015 interview observations.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Cantrall)	Held
Whether Cantrall proved not guilty by reason of insanity under R.C. 2901.01(A)(14) (must show by preponderance that, due to severe mental disease/defect, he did not know wrongfulness at time of offense)	The state argued the trial court correctly found defendant did not prove insanity because Dr. Grewal’s opinion that defendant knew wrongfulness was credible and based on contemporaneous acts and interviews	Cantrall argued Dr. Fabian’s review of St. Vincent records showed psychosis at the time of the acts and Dr. Grewal’s opinion was unreliable because she did not review those records and interviewed him months later (after medication), so reasonable minds could only conclude he was insane	Court affirmed: weight of evidence supports trial court’s finding that Cantrall failed to prove insanity; reasonable minds could credit Grewal’s conclusions that he knew wrongfulness

State v. Taylor, 98 Ohio St.3d 27 (Ohio 2002) (insanity is affirmative defense burdened by preponderance standard)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest‑weight review addresses witness credibility)
State v. Thomas, 70 Ohio St.2d 79 (Ohio 1982) (trier of fact decides credibility on insanity defense)
State v. Ross, 92 Ohio App. (Ohio App. — appellate discussion that insanity questions generally for trier of fact)
State v. Robinson, 162 Ohio St. (Ohio 1955) (distinguishing sufficiency and weight of the evidence)