In re Contempt of Donegan

2024 Ohio 840
CourtOhio Court of Appeals
DecidedMarch 7, 2024
Docket112779
StatusPublished

This text of 2024 Ohio 840 (In re Contempt of Donegan) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Contempt of Donegan, 2024 Ohio 840 (Ohio Ct. App. 2024).

Opinion

[Cite as In re Contempt of Donegan, 2024-Ohio-840.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

CONTEMPT OF : ROBERT O. DONEGAN : Nos. 112779 and 112797

[Appeal by Attorney Robert O. Donegan : and Jacob Hernandez in matter styled: State of Ohio v. Jacob Hernandez] :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED RELEASED AND JOURNALIZED: March 7, 2024

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-22-674608-A

Appearances:

Koblentz & Penvose, LLC, Nicholas E. Froning, and Richard S. Koblentz, for appellant Robert O. Donegan.

Russell S. Bensing, for appellant Jacob Hernandez.

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Gregory J. Ochocki, Assistant Prosecuting Attorney, for appellee.

EMANUELLA D. GROVES, J.:

In this consolidated case, attorney Robert O. Donegan (“Donegan”)

appeals the trial court’s decision finding him in contempt of court. Jacob Hernandez (“Hernandez”) appeals the trial court’s decision removing his retained counsel,

Donegan. For the reasons that follow, we reverse both decisions of the trial court.

Factual and Procedural History

On October 4, 2022, a grand jury indicted Hernandez for one count of

rape, a felony of the first degree. Donegan filed a notice of appearance as attorney

for Hernandez on October 18, 2022. The case was scheduled for multiple pretrials

and continued due to ongoing discovery. On March 28, 2023, the case was set for

trial on April 19, 2023, but was then canceled and rescheduled for May 30, 2023.

On March 31, 2023, the parties filed a joint motion for continuance, which the trial

court denied. On April 4, 2023, the trial court canceled the May 30, 2023 trial date

and rescheduled the trial for the original date, April 19, 2023. On April 18 and 19,

2023, the state filed supplementary discovery responses.

On April 19, 2023, the parties appeared in court for a pretrial. At the

time, Donegan informed the court, and the state confirmed, that he received the

DNA test results and a copy of the phone dump from his client’s phone the day

before trial. Additionally, that morning, the state notified Donegan that in exchange

for a plea of guilty they would amend the charge to one count of sexual battery, a

felony of the third degree. When asked, Donegan indicated that he had not

discussed the offer with Hernandez because he wanted to review the newly acquired

evidence first. The court then inquired whether Donegan had ever handled a rape

case or a first-degree felony case. Donegan informed the court that he had not done

so. The trial was continued to May 22, 2023. The trial commenced on May 22, 2023, at 1:30 p.m. Trial court’s May

2, 2023 Journal Entry. After discussing some preliminary matters, jury selection

began. During the course of jury selection, the trial court suggested to the jury that

they bring their lunches to court on May 23, 2023. Tr. 91, 113-114. The court also

suggested the jurors could eat at home or eat in the car on the way to court. Tr. 113-

114. Thereafter, the state completed questioning the jury, and the trial court

adjourned for the day. The court instructed the jurors to return to court the next

day by 12:45 p.m. The trial court did not separately notify the attorneys of a time for

arrival.

On May 23, 2023, the trial court went on the record at approximately

1:12 p.m. At that time, Donegan was not present in court; however, Hernandez and

the prosecutor were. Hernandez told the court he had texted Donegan about his

whereabouts, and Donegan responded that he was on his way and should be in the

courtroom shortly. At 1:30 p.m., the court was on the record in another case when

Donegan entered the courtroom. The trial court asked the other parties to step aside

in order to address Donegan directly. The court noted that Donegan was half an

hour late. Donegan apologized and informed the court that he thought the start time

would be 1:30 p.m., due to the drug court docket.

The trial court then began to go over some history of the case and

questioned Donegan. The court noted a prior court date where Donegan had a

cousin call the court to request a continuance. Donegan acknowledged that his

cousin did call and requested a continuance on his behalf. The court asked, and Donegan confirmed, that at a previous pretrial, he

had not immediately communicated the plea offer to his client. The court then asked

if Donegan knew what time the court asked the jury to return. Donegan confirmed

that the jury was to return at 12:45 p.m. Donegan explained that he assumed they

were on the same schedule as the previous day. After this exchange, the court found:

Trial Court: Mr. Hernandez [sic], I find you to be in direct contempt of this court for your failure to appear for trial on the second day.

Trial Court: I’m going to declare a mistrial, as extreme misgivings based upon your behavior today and on your behavior up to this point on this case, that you are able to adequately represent Mr. Hernandez.

Trial Court: I will allow you to purge that finding of criminal contempt, direct contempt, with you fully refunding your client’s retainer, by paying all the court costs on this case up to this point, including the jury’s appearance fees, and going down to the court’s lab on the first floor across the street and giving them a urine sample at this point.

Trial Court: Do you understand me?

Donegan: Yes, Your Honor.

Trial Court: Okay. Mr. Hernandez, I’m going to appoint Walt Edwards to represent you. We will get a trial date for you in a little bit after Mr. Edwards has a chance to get up to speed on this.

Trial Court: Counselor, is there anything else?

State: No, Your Honor.

Trial Court: Good luck, Mr. Donegan. You’ve spent too much money on your legal education to throw it away at this point.

The trial court subsequently filed a journal entry as follows:

On the second day of trial, counsel for the defendant failed to appear in a timely manner. On the first day of trial the jury was instructed to return at 12:45 p.m., so that trial could begin at approximately 1:00 p.m., after the court had finished its morning Drug Court Docket. Robert Donegan did not appear until 1:30 p.m. Mr. Donegan did not call the court to indicate he was going to be late. Additionally, Mr. Donegan failed to inform his client that he would be late. His client was here prior to 1:00 and had to text Mr. Donegan as to his whereabouts. The court finds Mr. Donegan in contempt. The court [is] aware through prior on the record conversations that Mr. Donegan has not ever handled a rape case, nor a first-degree felony prior to being retained by the defendant, had concerns about the attorney’s competence to handle this weighty case. This court orders a mistrial and removes Mr. Donegan from representing the defendant due to his failure to demonstrate the competence necessary to represent a defendant charged with a first-degree felony. The contempt may be purged with proof of a full refund of the defendant’s retainer, the payment of all of the court costs incurred by the defendant up to May 23, 2023, and a self-report by Mr. Donegan to the court’s lab to supply a sample for testing.

On May 25, 2023, and May 31, 2023, respectively, Donegan and

Hernandez appealed the trial court’s May 23, 2023 order and now raise the

following assignments of error for our review.

Donegan’s Assignment of Error No. 1

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2024 Ohio 840, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-contempt-of-donegan-ohioctapp-2024.