State v. Mitchell
2016 Ohio 7691
Ohio Ct. App. 9th2016Background
- Defendant Ryan D. Mitchell shot and killed his girlfriend, Melissa Nilson, at close range in February 2014, fled in her car, crashed, and was captured after a foot chase and struggle with police.
- Mitchell conceded the acts but raised a not-guilty-by-reason-of-insanity (NGRI) defense at trial; the jury convicted him of felony murder, grand theft, assault on an officer, having a weapon while under disability, and a firearm specification.
- Three forensic psychologists testified: defense expert Barbara Bergman diagnosed schizoaffective disorder (bipolar type) and opined Mitchell could not tell right from wrong; prosecution experts Thomas Martin and Massimo De Marchis concluded Mitchell either was malingering or, even if mentally ill, knew the wrongfulness of his acts.
- Key contested facts included Mitchell’s pre- and post-shooting statements and behaviors, psychological testing (SIRS and MMPI results), drug history (trace Xanax only), and whether his conduct was goal-directed evincing knowledge of wrongfulness.
- The jury rejected the insanity defense and the trial court sentenced Mitchell to an aggregate of 22.5 years to life. Mitchell appealed raising three assignments of error.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Mitchell) | Held |
|---|---|---|---|
| Whether jury verdict rejecting NGRI is against manifest weight | Evidence (admissions, goal-directed flight, expert testimony) supports finding Mitchell knew wrongfulness | Bergman’s unrefuted opinion showed severe mental illness preventing knowledge of wrongfulness; evidence was conflicting | Court held verdict not against manifest weight; credited prosecution experts and Mitchell’s statements/actions to support knowing wrongfulness |
| Whether trial court erred by refusing drug-related NGRI jury instruction | No abuse: insufficient evidence of intoxication or drug-induced disease; experts did not opine drug-caused defect | Requested Ohio Jury Instr. re: drug-caused insanity should be given because drug-induced psychosis was possible | Court held refusal not an abuse of discretion given trace drug in system, no expert diagnosis of drug-caused defect, and only speculation by one expert |
| Whether trial court’s paraphrase of R.C. 2945.391 (irresistible impulse) was erroneous | Instruction correctly paraphrased statute and did not prejudice defendant | Paraphrase omitted word "proof" and could bar irresistible-impulse claims | Court held paraphrase substantively equivalent and not prejudicial; irresistible-impulse is not a basis for insanity under Ohio law |
| Whether trial counsel was ineffective for not objecting to expert’s characterization of antisocial personality disorder as "habitual criminal" | No deficiency or prejudice: testimony explained disorder and was admissible; defense could cross-examine | Characterization prejudiced jury and counsel should have objected | Court held no ineffective assistance: testimony permissible and any remark was not outcome-determinative given the violent facts and central expert dispute |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for manifest-weight review)
- State v. Martin, 20 Ohio App.3d 172 (1st Dist. 1983) (manifest-weight reversal limited to exceptional cases)
- State v. DeHass, 10 Ohio St.2d 230 (1967) (deference to factfinder on witness credibility)
- State v. Adams, 144 Ohio St.3d 429 (2015) (standard for giving requested jury instructions)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance test)
- State v. Bradley, 42 Ohio St.3d 136 (1989) (prejudice prong discussion under Strickland for Ohio)