State v. Smith, 2021 Ohio 1389

In 2015 William Smith was charged with killing two friends; he claimed self-defense but was convicted of two counts of murder at a 2017 trial and his convictions were affirmed on direct appeal.
Post-appeal, Smith filed an application under R.C. 2953.71 et seq. seeking DNA testing of clothing bloodstains to support his self-defense theory.
The trial court denied the application in a two-sentence order stating only that the application was “not well taken,” offering no reasons.
R.C. 2953.73(D) requires the trial court, upon accepting or rejecting a DNA-testing application, to enter a judgment that includes the reasons for the acceptance or rejection.
Appellate precedent recognizes that the court need not issue formal findings and conclusions, but the denial must include more than a cursory statement and must state reasons tied to the statutory criteria.
The First District found the trial court’s order provided no reasons, concluded that omission was an abuse of discretion, sustained Smith’s challenge, and remanded with instructions to explain the denial; Smith’s separate ineffective-assistance argument was deemed moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying Smith’s DNA-testing application without stating reasons as required by R.C. 2953.73(D)	The State defended the denial as within the trial court’s discretion and courts need not make formal findings of fact and conclusions of law	Smith argued the statute compels the trial court to state reasons for accepting or rejecting the application, facilitating appellate review	The court held the denial was an abuse of discretion because the trial court gave no reasons; remanded for the trial court to explain its denial
Whether Smith was entitled to DNA testing based on ineffective assistance of counsel	State would argue insufficient basis for testing	Smith argued ineffective assistance warranted testing	Moot (court did not decide on merits because remand was required for lack of reasons)

State v. Conner, 158 N.E.3d 162 (Ohio App.) (failure to provide reasons for rejecting a DNA-testing application is contrary to law and constitutes an abuse of discretion)
State v. Price, 165 Ohio App.3d 198 (1st Dist.) (trial court need not use formal findings and conclusions, but must provide reasons beyond a cursory statement)