State v. Williams, 2023 Ohio 965

James D. Williams IV was indicted in two Greene County cases: aggravated possession (May 13, 2022) and aggravated arson (July 15, 2022); the State sought denial of bail in the arson case citing an extensive, documented history of mental-health concerns and repeated 911 delusion-driven calls.
Defense counsel filed a motion for a competency and sanity evaluation in the possession case; the record also shows the trial court granted a competency evaluation in the arson case before the evaluation occurred.
A forensic evaluation (Sept. 2, 2022) concluded Williams was seriously mentally ill, not intellectually disabled, had fixed paranoid and grandiose delusions, could understand factual aspects of proceedings but could not rationally appreciate them or assist in his defense, and was therefore incompetent to stand trial.
At the Oct. 6, 2022 competency hearing, retained counsel moved to withdraw for an irretrievable breakdown in communication; the court removed counsel, appointed new counsel over Williams’s objections, and Williams orally requested to represent himself.
The trial court found Williams incompetent and committed him for restoration treatment at Summit Behavioral Healthcare; Williams appealed, challenging (1) the competency hearing/order and (2) the denial of his request to proceed pro se.

Issue	Williams' Argument	State's Argument	Held
Whether the trial court erred in ordering a competency hearing/evaluation	No reasonable basis to doubt competency; evaluation/hearing unnecessary	Competency was properly raised and the court may order evaluation and hold a hearing; competency order is reviewable as final when commitment follows	Court: defense counsel’s motion in the possession case and the State’s no-bail memorandum as to arson adequately raised competency; hearing and evaluation were appropriate and the competency determination/commitment is appealable — affirmed
Whether Williams’ Sixth Amendment right to self-representation was violated when court appointed counsel over his objection	He orally requested to represent himself after retained counsel withdrew; court improperly denied that request	The issue is not part of the appealed competency order; appointment of counsel was in a separate entry and not yet a final appealable order	Court: issue not properly before this appeal (limited to competency/commitment order); denial of self-representation can be appealed after final judgment — not decided on merits

State v. Muncie, 91 Ohio St.3d 440 (explaining the meaning of "order" and provisional remedies under R.C. 2505.02)
State v. Upshaw, 110 Ohio St.3d 189 (holding that an order finding incompetency and committing for restoration is a final appealable order)
State v. Thomas, 97 Ohio St.3d 309 (discussing due-process prohibition on trying legally incompetent defendants)
State v. Smith, 89 Ohio St.3d 323 (noting that a defendant lacking capacity to understand proceedings may not be tried)
Drope v. Missouri, 420 U.S. 162 (federal constitutional precedent on competency to stand trial)
State v. Bock, 28 Ohio St.3d 108 (incompetency distinct from mere mental instability or psychosis)
State v. Lawson, 165 Ohio St.3d 445 (statutory requirement that a hearing be held when competency is raised before trial)