State v. Stutzman, 2019 Ohio 1695

In 2011 Rodney Stutzman was charged with capital murder after the bodies of his parents were found; physical evidence tied him to the scene and a handwritten note matched his handwriting.
Defense counsel raised competency concerns; Dr. Galit Askenazi (defense) evaluated Stutzman and the trial court initially found him incompetent and committed him to Twin Valley for restoration.
Multiple state experts (including Drs. Stinson, Smith, Tilley, Soehner, and others) later evaluated Stutzman and consistently opined he was malingering and likely competent; Askenazi repeatedly maintained he remained incompetent.
Over several years the court conducted multiple competency reviews, retained jurisdiction under R.C. 2945.39, and repeatedly committed Stutzman to Twin Valley; testimony at the most recent hearing again split between State experts (malingering) and Askenazi (incompetent).
The trial court issued a short journal entry finding Stutzman remained incompetent but did not set out the factual findings or credibility determinations explaining how it weighed competing expert testimony.
The State appealed; the Ninth District reversed and remanded solely because the trial court failed to make and record factual findings and credibility determinations necessary for meaningful appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in finding Stutzman remained incompetent to stand trial	State: overwhelming evidence (multiple State experts, objective malingering tests, long staff observations) showed competence	Stutzman: defense expert Askenazi maintained he suffered delusions and lacked ability to assist counsel, so remained incompetent	Reversed and remanded — court erred because it failed to make factual findings/credibility determinations enabling appellate review
Standard and burden for competency	State: defendant must prove incompetence by preponderance but State argued evidence showed competence	Stutzman: argued evidence supports incompetence finding	Court explained legal standard (presumption of competence; defendant bears burden) and emphasized need for trial-court factual findings
Deference to trial-court factual findings on competency	State: trial court should be respected if findings supported by evidence	Stutzman: trial court had previously credited defense expert	Court: generally defers to trial-court factfinding but cannot review absent explicit findings; remanded for findings
Whether expert opinion can be disregarded	State: trial court could rely on State experts and objective tests	Stutzman: urged court to credit defense expert despite State tests	Court: trial courts may reject expert testimony but must provide objective reasons when doing so; lack of stated reasons required reversal

State v. Were, 118 Ohio St.3d 448 (2008) (defendant bears burden to prove incompetence by preponderance)
State v. Berry, 72 Ohio St.3d 354 (1995) (Dusky standard described: ability to consult with counsel and rational/factual understanding)
State v. Roberts, 137 Ohio St.3d 230 (2013) (competency is a question of fact)
State v. Cowans, 87 Ohio St.3d 68 (1999) (deference to trial court on factual findings and demeanor-based credibility)
State v. Neyland, 139 Ohio St.3d 353 (2014) (trial judge assesses expert credibility and weighs evidence)
State v. White, 118 Ohio St.3d 12 (2008) (expert opinion cannot be arbitrarily ignored; reasons required)
State v. Ferguson, 108 Ohio St.3d 451 (2006) (mental instability or need for medication alone does not show incompetence)
State v. Bock, 28 Ohio St.3d 108 (1986) (same principle regarding presumption of competence)
Dusky v. United States, 362 U.S. 402 (1960) (establishes competency standard)
United States v. Hall, 583 F.2d 1288 (5th Cir.) (expert opinion may not be ignored without objective reason)