State v. Harris, 2022 Ohio 933

Shayla Harris was indicted on 14 counts arising from three April 2020 hit-and-run incidents that injured multiple people and two dogs (charges included attempted murder, felonious assault, and animal mistreatment).
The trial court ordered a competency evaluation and transferred the case to the mental-health docket.
On the plea date the parties stipulated to a court-psychiatric-clinic competency report finding Harris competent; the court noted the stipulation on the record and in its journal entry.
Harris pleaded guilty to two counts of felonious assault (F2), two counts of attempted murder (F1), and two counts of animal mistreatment (M1).
The court sentenced Harris under the Reagan Tokes Law to an indeterminate term of 9 to 13.5 years.
Harris appealed, raising (1) that the court failed to properly find her competent before accepting her plea, and (2) that sentencing under the Reagan Tokes Law is unconstitutional.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by accepting Harris’s plea without making an explicit competency finding on the record	State: Competency was established by a stipulated psychiatric report; when parties stipulate, a full competency hearing and additional findings are not required	Harris: Court did not make a contemporaneous finding that she was competent before accepting the plea; relies on Whitling to argue journalized finding is required	Court: Overruled. Because competency is presumed, parties stipulated to the clinic report, and the stipulation was recorded in the journal, no additional hearing or extra on-the-record finding was required
Whether sentencing under the Reagan Tokes Law is unconstitutional	State: Reagan Tokes is constitutional and applicable; precedent supports its validity	Harris: Reagan Tokes violates due process and separation-of-powers principles	Court: Overruled. Relied on this court’s en banc decision in Delvallie upholding the statute

State v. Roberts, 998 N.E.2d 1100 (Ohio 2013) (defendant bears burden to prove incompetency by a preponderance; competency presumed)
State v. Were, 761 N.E.2d 591 (Ohio 2002) (when competency is raised, statute directs the court to hold a competency hearing)
State v. Whitling, 110 N.E.3d 63 (Ohio 2018) (trial court’s failure to journalize competency finding can invalidate plea when court does not otherwise record a reliable competency determination)
State v. Lewis, 84 N.E.3d 294 (Ohio 2017) (interpreting competency procedures and supporting that stipulations can render additional hearings unnecessary)