State v. Bernardo

2025 Ohio 1399
CourtOhio Court of Appeals
DecidedApril 17, 2025
Docket2024 CA 00088
StatusPublished

This text of 2025 Ohio 1399 (State v. Bernardo) 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
State v. Bernardo, 2025 Ohio 1399 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Bernardo, 2025-Ohio-1399.]

COURT OF APPEALS LICKING COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO : JUDGES: : Hon. William B. Hoffman, P.J. Plaintiff - Appellee : Hon. Robert G. Montgomery, J. : Hon. David M. Gormley, J. -vs- : : CAMERON L. BERNARDO : Case No. 2024 CA 00088 : Defendant - Appellant : OPINION

CHARACTER OF PROCEEDING: Appeal from the Licking County Court of Common Pleas, Case No. 2024 CR 00140

JUDGMENT: Affirmed

DATE OF JUDGMENT: April 17, 2025

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

Kenneth W. Oswalt Brian A. Smith Assistant Prosecuting Attorney 123 South Miller Road 20 South Second Street, 4th Floor Suite 250 Newark, Ohio 43055 Fairlawn, Ohio 44333 Gormley, J.

{¶1} Defendant Cameron L. Bernardo was convicted of attempted murder and

felonious assault at a bench trial in Licking County after the trial judge concluded — based

on the views of two experts — that Bernardo had failed to prove his affirmative defense

of insanity. Bernardo now appeals, contending that the trial judge misinterpreted the

experts’ conclusions. Finding that the trial judge’s interpretation was supported by the

weight of the evidence, we now affirm.

Facts and Procedural History

{¶2} In February 2024, Bernardo visited the home of his grandmother to wash

his laundry. His mother and his mother’s boyfriend also happened to be staying at the

home at that time. Bernardo, believing that his family was abusing his daughter, started

arguing with his mother.

{¶3} Bernardo then attacked his mother with a pocketknife, stabbing her once in

the head, once in the neck, and multiple times in the chest and arms. His mother

managed to escape the attack and call for help, and she survived her wounds.

{¶4} Bernardo left the home on foot and was apprehended by police officers

several blocks away. Police found a bloody knife in Bernardo’s pocket and saw blood on

his hands, clothing, and chest. Bernardo told the officers that he had stabbed his mother.

{¶5} Bernardo was charged with attempted murder and felonious assault. He

pled not guilty by reason of insanity, and the trial judge ordered that a psychological

evaluation be done. That evaluation was performed by psychologist Emily Weber, who

concluded that, because of symptoms of a severe mental disease, Bernardo likely did not

understand the wrongfulness of his actions at the time he attacked his mother. Weber’s written report noted that she was unable to determine the cause of those symptoms, but

her report did indicate that Bernardo’s symptoms were consistent with voluntary

intoxication.

{¶6} Bernardo requested, and the trial judge ordered, a second psychological

evaluation. That evaluation, performed by psychologist Amanda Conn, also indicated

that, due to psychotic symptoms, Bernardo likely did not understand the wrongfulness of

his actions at the time of the attack. Like the Weber evaluation, the Conn evaluation

noted that the psychotic symptoms could have been the result of chemically induced

voluntary intoxication.

{¶7} The case proceeded to a bench trial, where the parties agreed on the facts

and the admissibility of the two experts’ reports. Neither party offered witness testimony

at the trial, and both Bernardo and the state recommended that the trial judge find

Bernardo not guilty by reason of insanity. The trial judge, however, concluded that

Bernardo had failed to meet his burden of proof on that affirmative defense, and the judge

found Bernardo guilty of both attempted murder and felonious assault. Bernardo now

appeals.

Bernardo’s Conviction Was Not Against the Manifest Weight of the Evidence

{¶8} In his sole assignment of error, Bernardo contends that his conviction was

against the manifest weight of the evidence because, according to him, the trial judge

incorrectly weighed the Weber and Conn evaluations.

A. The Manifest-Weight Standard of Review

{¶9} “In determining whether a conviction is against the manifest weight of the

evidence, the court of appeals functions as the ‘thirteenth juror,’ and after ‘reviewing the entire record, weighs the evidence and all reasonable inferences, considers the credibility

of witnesses and determines whether in resolving conflicts in the evidence, the jury clearly

lost its way and created such a manifest miscarriage of justice that the conviction must

be overturned and a new trial ordered.’” State v. Hane, 2025-Ohio-120, ¶ 20 (5th Dist.),

quoting State v. Thompkins, 78 Ohio St.3d 380, 387 (1997).

{¶10} “In weighing the evidence, the court of appeals must always be mindful of

the presumption in favor of the finder of fact.” State v. Butler, 2024-Ohio-4651, ¶ 75 (5th

Dist.). “[A]n appellate court will leave the issues of weight and credibility of the evidence

to the factfinder, as long as a rational basis exists in the record for its decision.” State v.

Sheppard, 2025-Ohio-161, ¶ 66 (5th Dist.).

{¶11} “‘The weight to be given the evidence and the credibility of the witnesses

who provide opinions regarding the defense of insanity in a criminal proceeding are

primarily for the trier of fact.’” State v. Fenderson, 2010-Ohio-2240, ¶ 37 (5th Dist.),

quoting State v. Curry, 45 Ohio St.3d 109, 114 (1989). “‘If the evidence is susceptible of

more than one construction, the reviewing court is bound to give it that interpretation

which is consistent with the verdict and judgment, most favorable to sustaining the verdict

and judgment.’” State v. Williams, 2024-Ohio-5578, ¶ 62 (5th Dist.), quoting Seasons

Coal Co., Inc. v. City of Cleveland, 10 Ohio St.3d 77, 80, fn 3 (1984).

B. The Not-Guilty-by-Reason-of-Insanity Defense

{¶12} Under Ohio law “[a] person is ‘not guilty by reason of insanity’ relative to a

charge of an offense only if the person proves . . . that at the time of the commission of

the offense, the person did not know, as a result of a severe mental disease or defect,

the wrongfulness of the person’s acts.” R.C. 2901.01(A)(14). Insanity is an affirmative defense that must be proved by the defendant by a preponderance of the evidence. State

v. McConnell, 2021-Ohio-41, ¶ 21 (5th Dist.), citing State v. Eick, 2011-Ohio-1498, ¶ 29

(5th Dist.).

{¶13} “Where the insanity is simply a temporary condition brought on by the

voluntary ingestion of drugs or alcohol, it does not suffice to establish an NGRI defense.”

State v. Swanson, 2014-Ohio-549, ¶ 14 (6th Dist.). See also State v. Toth, 52 Ohio St.2d

206, 210 (1977) (“It is a well-established rule in Ohio that the defense of insanity cannot

be successfully established simply on the basis that the condition resulted from the use

of intoxicants or drugs, where such use is not shown to be habitual or chronic”).

C. The Trial Judge Had a Rational Basis to Conclude That Bernardo Did Not Establish the Defense of Insanity

{¶14} The weight of the evidence at Bernardo’s bench trial supports the trial

judge’s conclusion that Bernardo’s mental condition at the time of the attack was caused

by voluntary intoxication rather than a severe mental disease or defect.

{¶15} We note, at the outset, that the Weber and Conn evaluations were

inconclusive as to the cause of Bernardo’s mental condition at the time of the attack. The

Weber report, which explained that “the weight of the data suggest[s] [that symptoms of

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Related

State v. Eick
2011 Ohio 1498 (Ohio Court of Appeals, 2011)
State v. McConnell
2021 Ohio 41 (Ohio Court of Appeals, 2021)
State v. Toth
371 N.E.2d 831 (Ohio Supreme Court, 1977)
Seasons Coal Co. v. City of Cleveland
461 N.E.2d 1273 (Ohio Supreme Court, 1984)
State v. Curry
543 N.E.2d 1228 (Ohio Supreme Court, 1989)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)
State v. Williams
2024 Ohio 5578 (Ohio Court of Appeals, 2024)
State v. Hane
2025 Ohio 120 (Ohio Court of Appeals, 2025)
State v. Sheppard
2025 Ohio 161 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1399, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bernardo-ohioctapp-2025.