State v. Smith
2020 Ohio 3666
Ohio Ct. App.2020Background
- James Smith was indicted on multiple counts including murder and tampering with evidence; he was referred for competency evaluation after counsel raised competency concerns.
- An initial court clinic evaluation was inconclusive; Smith was sent to Northcoast for inpatient evaluation, where a psychiatrist reported Smith competent to stand trial.
- The parties stipulated to the psychiatric findings on the record and in a January 23, 2019 journal entry, though the Northcoast report is not in the appellate file.
- On June 26, 2019 Smith pleaded guilty to murder (with a repeat violent offender specification) and tampering with evidence; remaining counts were nolled.
- The court accepted the plea, waived the PSI, and sentenced Smith the next day to consecutive terms totaling 23 years to life.
- Smith appealed, arguing (1) no competency hearing/finding after clinic referral and (2) the court failed to make required consecutive-sentence findings under R.C. 2929.14.
Issues
| Issue | State's Argument | Smith's Argument | Held |
|---|---|---|---|
| Whether Smith’s guilty plea must be vacated because competency was not determined after clinic referral | Parties stipulated to the psychiatric findings showing competence; no additional hearing was required | No record shows a competency finding or that the parties stipulated competency; plea therefore invalid | Court held competency was properly addressed: parties stipulated to psych findings and record supports competence; plea valid |
| Whether the trial court failed to make statutory findings to impose consecutive sentences | Court made required findings at sentencing and incorporated them into the journal entry; language need not mirror statute verbatim | Journal entry language differed from oral findings and was a mere blanket statement, so findings are inadequate | Court held the trial court made the R.C. 2929.14(C)(4) findings on the record and in the entry; consecutive sentences affirmed |
Key Cases Cited
- State v. Bolin, 128 Ohio App.3d 58, 713 N.E.2d 1092 (8th Dist. 1998) (a defendant not competent to stand trial is not competent to enter a negotiated plea)
- State v. Roberts, 137 Ohio St.3d 230, 998 N.E.2d 1100 (2013) (competency is presumed and defendant bears burden to prove incompetence)
- State v. Were, 94 Ohio St.3d 173, 761 N.E.2d 591 (2002) (trial court must hold competency hearing when competency is raised)
- State v. Bonnell, 140 Ohio St.3d 209, 16 N.E.3d 659 (2014) (trial court must make and journal statutory findings for consecutive sentences; exact statutory wording not required)