State v. Walker, 2023 Ohio 140

Appellant Skyler Walker was indicted in two consolidated cases for offenses against the same victim: abduction (third-degree felony) and felonious assault (second-degree felony) after two separate assaults while on bond.
On November 29, 2021 Walker entered guilty pleas pursuant to North Carolina v. Alford; the state dismissed other charges/specifications as part of the plea agreement.
The trial court ordered a presentence investigation and granted defense counsel’s post-plea request for a psychological evaluation. Dr. Wynkoop evaluated Walker.
At sentencing the court reviewed the PSI, victim impact materials, letters, and the diagnostic report; the court imposed consecutive terms (30 months + indefinite 6–9 years) totaling 8.5–11.5 years.
Walker appealed, raising two assignments of error: (1) the trial court failed to make required statutory findings for consecutive sentences under R.C. 2929.14(C)(4); and (2) ineffective assistance of counsel for not seeking a pre-plea competency evaluation and for failing to enter a not-guilty-by-reason-of-insanity (NGRI) plea.

Issue	Plaintiff's Argument (Walker)	Defendant's Argument (State)	Held
Whether the trial court made the required R.C. 2929.14(C)(4) findings before imposing consecutive sentences	Walker: court failed to make proper findings to support consecutive terms	State: court made all required findings on necessity, proportionality, and applicability of subsections (b) and (c), both at hearing and in the entries	Court: Affirmed — trial court expressly found necessity to protect/punish, proportionality, course-of-conduct harm, and criminal history; findings appear in transcript and entries
Whether trial counsel rendered ineffective assistance by not requesting a pre-plea competency evaluation and by not pleading NGRI	Walker: counsel should have sought competency evaluation and entered NGRI given bipolar disorder and alleged drug use/medication noncompliance	State: no indicia of incompetency in the record; counsel reasonably filed a post-plea psych eval; NGRI had low likelihood of success given record and evidence of knowing wrongfulness	Court: Affirmed — no deficient performance or prejudice under Strickland; no record indicia of incompetency; NGRI unlikely to succeed (voluntary intoxication and conduct showing awareness of wrongfulness)

North Carolina v. Alford, 400 U.S. 25 (1970) (permitting a guilty plea while maintaining innocence under certain conditions)
Strickland v. Washington, 466 U.S. 668 (1984) (two-part test for ineffective assistance of counsel)
Blackledge v. Allison, 431 U.S. 63 (1977) (statements made during plea colloquy carry a strong presumption of verity)
State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial court must make statutory consecutive-sentence findings on the record and in the judgment entry)
State v. Beasley, 158 Ohio St.3d 497 (2018) (summarizing consecutive-sentencing standard and Bonnell requirements)
State v. Lawson, 165 Ohio St.3d 445 (2021) (discussing competency standards and ineffective-assistance claims related to competency)