State v. Mills, 2022 Ohio 969

Miguel Lamont Mills was indicted for felonious assault with a firearm specification and for discharging a firearm on/near a public road after witnesses and video showed an African‑American male chasing a white GMC SUV and firing shots that struck the vehicle.
Mills pleaded not guilty; voir dire began December 9, 2019. Multiple witnesses identified Mills in the videos; police found a bullet hole in the victim’s vehicle. The victim did not appear at trial.
Before trial Mills’ counsel filed a motion for a competency evaluation; the court referred Mills to the Court Diagnostic and Treatment Center but Mills refused transportation for the exam. No competency hearing was held.
During jury selection the prosecutor used a peremptory strike to remove an African‑American prospective juror (Juror No. 4); Mills raised a Batson objection and the court found the proffered reasons race neutral. The seated jury included one African‑American.
The jury convicted Mills on both counts and the firearm specification; the trial court sentenced him to a mandatory consecutive firearm term. Mills filed a delayed appeal raising four assignments of error.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Mills)	Held
1) Failure to hold competency hearing	Even though competency was raised, Mills thwarted the evaluation by refusing transport; record shows no indicia of legal incompetence	Trial court should have held a mandatory competency hearing after counsel filed a motion	Harmless/no reversible error — Mills was not shown legally incompetent; refusal to cooperate supported proceeding to trial
2) Batson challenge to peremptory strike of juror No. 4	Strike was race‑neutral: juror equivocated about ability to render judgment and said conscience would impair deliberation	Strike was pretextual; removal eliminated African‑American representation	Denied — trial court credited race‑neutral explanation; no clear error in its Batson ruling
3) Sufficiency of evidence (firearm/assault)	Videos, eyewitness ID, gunshot sounds, visual flashes, and bullet hole permit a rational juror to find elements beyond a reasonable doubt	State failed to prove Mills possessed or used a firearm; videos do not clearly show a gun	Convictions supported — evidence sufficient when viewed in light most favorable to the prosecution
4) Manifest weight of the evidence	Jury reasonably believed eyewitnesses and video; verdict not a miscarriage of justice	Verdict against manifest weight because state didn’t prove firearm use	Denied — appellate court will not reweigh credibility; not an exceptional case to reverse

Batson v. Kentucky, 476 U.S. 79 (1986) (three‑step test for racial discrimination in peremptory strikes)
Miller‑El v. Cockrell, 537 U.S. 322 (2003) (explains burden‑shifting and evaluation of Batson explanations)
Powers v. Ohio, 499 U.S. 400 (1991) (defendant need not share race of excused juror to raise equal‑protection challenge)
Jackson v. Virginia, 443 U.S. 307 (1979) (legal sufficiency standard: whether any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Bock, 28 Ohio St.3d 108 (1986) (competency hearing required when competency raised; distinguishes emotional disturbance from legal incompetence)
State v. Berry, 72 Ohio St.3d 354 (1995) (mental illness does not necessarily equal legal incompetence)
State v. Jenks, 61 Ohio St.3d 259 (1991) (Jackson standard adopted for sufficiency review)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest‑weight standard; appellate court as thirteenth juror)
State v. Johnson, 144 Ohio St.3d 518 (2015) (deference to trial court on Batson credibility and plausibility)
State v. Lawson, 179 N.E.3d 1216 (Ohio 2021) (harmlessness analysis where competency hearing not held)