State v. Reynolds
2017 Ohio 1478
| Ohio Ct. App. | 2017Background
- Defendant Lecorius Reynolds, diagnosed with schizoaffective disorder, stabbed and killed Roy Roberts; Reynolds moved the body to railroad tracks and was arrested within 24 hours after a recorded police interview in which he confessed.
- Physical and forensic evidence: extensive blood at defendant’s residence, blood trail, victim’s defensive wound, victim’s blood on a recovered knife, and victim DNA on a swab from Reynolds’ forearm.
- Reynolds claimed self-defense and asserted a not-guilty-by-reason-of-insanity (NGRI) affirmative defense; he had long psychiatric history and gaps in antipsychotic treatment.
- Defense expert (Dr. Fabian) testified Reynolds was psychotic at the time and that some post-offense acts were driven by voices; state expert (Dr. Rivera) testified Reynolds displayed goal-directed, non-psychotic behavior and understood wrongfulness.
- Trial court (bench trial) found Reynolds guilty of felony murder, rejected the insanity defense, and sentenced him to 15 years to life in a prison psychiatric unit.
- On appeal Reynolds argued (1) verdict against manifest weight because he proved insanity by a preponderance; and (2) ineffective assistance because counsel failed to move to suppress his videotaped confession as involuntary due to mental illness.
Issues
| Issue | Plaintiff's Argument (Reynolds) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether verdict is against manifest weight because Reynolds proved NGRI | Reynolds: was psychotic at the time, had delusions/voices motivating the killing, so he did not know wrongfulness | State: evidence of lucidity, coherent interview, and goal-directed concealment actions show he knew right from wrong | Held: Affirmed — trier of fact reasonably credited state expert and circumstantial evidence; verdict not against manifest weight |
| Whether trial counsel was ineffective for not moving to suppress confession as involuntary due to mental illness | Reynolds: mental illness rendered his Miranda waiver and confession involuntary; suppression motion would have succeeded | State: waiver and confession were voluntary; no police coercion or exploitation of illness; counsel’s strategy reasonable and no prejudice | Held: Affirmed — under Connelly/Hughbanks voluntariness turns on police overreaching; no coercion shown so motion would not have succeeded; no ineffective assistance |
Key Cases Cited
- Thompkins v. Ohio, 78 Ohio St.3d 380 (Ohio 1997) (standard for reviewing manifest-weight claims)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part test for ineffective assistance of counsel)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requirements for custodial warnings and waiver)
- Colorado v. Connelly, 479 U.S. 157 (U.S. 1986) (confession voluntariness focuses on police coercion, not defendant’s mental state alone)
- State v. Hughbanks, 99 Ohio St.3d 365 (Ohio 2003) (applies Connelly; police need not obtain psychiatric evaluation absent coercion)
- State v. Hancock, 108 Ohio St.3d 57 (Ohio 2006) (burden to prove insanity by preponderance; statutory standard)
- Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (standards for knowing and intelligent Miranda waiver)
- State v. Madrigal, 87 Ohio St.3d 378 (Ohio 2000) (failure to file suppression motion is not per se ineffective assistance)
- State v. Brown, 115 Ohio St.3d 55 (Ohio 2007) (suppression-motion omission constitutes ineffective assistance only if motion would have been granted)