State v. Neyland (Slip Opinion), 139 Ohio St. 3d 353

Neyland Jr. was convicted by a jury of two counts of aggravated murder and sentenced to death after the trial court accepted the jury's recommendations.
The murders occurred at Liberty Transportation in Perrysburg, Ohio, where Neyland shot Lazar outside after hours and then killed Smith inside his office; a gun linked to the killings was later found in Neyland's tractor.
Prior to the killings Neyland had a contentious history with Liberty Transportation and threatened violence if he was provoked.
Neyland underwent multiple competency evaluations; the court ultimately found him competent to stand trial despite differing expert opinions.
During trial, Neyland requested self-representation, restraints were used (leg shackles) with varying rulings on necessity, and evidence included weapons not directly tied to the murders; he also faced penalty-phase arguments and potential evidentiary issues about prior testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency to stand trial	Neyland contends the court abused its discretion; evidence showed mental illness affecting competency.	Neyland argues lack of sufficient reliable evidence to support competency.	Trial court did not abuse discretion; Neyland was competent.
Right to self-representation	Neyland sought to represent himself; timely unequivocal request was needed.	Court should have granted self-representation earlier or considered competency to represent himself.	Late, untimely request denied; no error.
Leg restraints at trial	Court ordered restraints without a compelling, record-supported need.	Restraints were necessary for security given Neyland's size and potential disruption.	First restraint not abused; second restraint error, but harmless; no reversal.
Ineffective assistance—suppression motions and search-warrant challenge	Counsel failed to file suppression motions challenging statements and motel-room search.	Such failures prejudiced Neyland’s defense.	No deficient performance; motions to suppress not warranted given evidence and exceptions.
Admission of former testimony in penalty phase (Crawford issue)	Former competency testimony admitted as rebuttal evidence; could violate confrontation rights.	Should not have admitted testimonial evidence without cross-examination.	No plain error; even if error, cumulative and harmless.

Berry v. State, 72 Ohio St.3d 354 (1995) (competency/mitigating-factor standards in capital cases)
Faretta v. California, 422 U.S. 806 (1975) (right to self-representation requires unequivocal waiver)
Dusky v. United States, 362 U.S. 402 (1960) (competency standard for trial defendants (present ability and understanding))
Deck v. Missouri, 544 U.S. 622 (2005) (legality of shackling not requiring a formal hearing in all cases)
Crawford v. Washington, 541 U.S. 36 (2004) (confrontation rights and admissibility of testimonial statements)