State v. Chapin

424 N.E.2d 317, 67 Ohio St. 2d 437, 21 Ohio Op. 3d 273, 1981 Ohio LEXIS 600
CourtOhio Supreme Court
DecidedAugust 5, 1981
DocketNo. 80-648
StatusPublished
Cited by98 cases

This text of 424 N.E.2d 317 (State v. Chapin) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Chapin, 424 N.E.2d 317, 67 Ohio St. 2d 437, 21 Ohio Op. 3d 273, 1981 Ohio LEXIS 600 (Ohio 1981).

Opinion

Locher, J.

I.

Appellant, in its proposition of law, asserts that “[w]here the issue of the defendant’s [appellee’s] competency to stand trial is raised after the trial has begun, the court shall hold a hearing on the issue only for good cause shown.” (Emphasis sic.) Stated otherwise, the issue presented herein is whether defense counsel’s sole and unsupported suggestion of incompetency after the commencement of trial, taken together with any then existing knowledge of appellee’s mental condition, met the requisite “good cause shown” standard, which would warrant a competency hearing.

We find merit in appellant’s contention that a hearing was not required in the instant cause.

R. C. 2945.37 reads, in pertinent part, as follows:

“(A) In a criminal action in a court of common pleas or municipal court, the court, prosecutor, or defense may raise the issue of the defendant’s competence to stand trial. If the issue is raised before trial, the court shall hold a hearing on the issue as provided in this section. If the issue is raised after trial [439]*439has begun, the court shall hold a hearing on the issue only for good cause shown. ” (Emphasis added.)

R. C. 2945.37 sets forth alternate tests for the allowance of a hearing concerning competency to stand trial depending upon when the suggestion of incompetency is raised. Appellant claims that, if the issue of competency to stand trial is raised prior to trial, the court shall hold a hearing, whereas, if the issue of competency to stand trial is raised after the commencement of trial, a hearing is allowed “only for good cause shown.”

The above-quoted section, effective November 1, 1978, substantially altered the law in this area. Former R. C. 2945.37 mandated that a hearing be held with no distinction as to whether the suggestion of incompetency to stand trial is made before or after trial.

Former R. C. 2945.37 read, in pertinent part, as follows:

“If the attorney for a person accused of crime whose cause is pending in the court of common pleas, before or after trial suggests to the court that such person is not then sane* * * or if it otherwise comes to the notice of the court that such person is not then sane, the court shall proceed to examine into the question of the sanity or insanity of said person, or in its discretion may impanel a jury for such purpose. * * * ”

It is elementary and quite clear that the General Assembly has altered the format for obtaining a hearing concerning competency to stand trial. The dichotomy created in the current R. C. 2945.37 simply allows for a hearing after the commencement of a trial “only for good cause shown.”

It is uncontroverted that the conviction of an accused person while he is legally incompetent violates due process. See Bishop v. United States (1956), 350 U. S. 961. The United States Supreme Court, in Dusky v. United States (1960), 362 U. S. 402, set forth the test to determine whether a defendant is competent to stand trial. The court, at page 402, stated:

“***the ‘test must be whether he has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding—and whether he has a rational as well as factual understanding of the proceedings against him.’ ”

The parties herein are also acutely aware that the evidence of appellee’s irrational behavior, his demeanor at trial and any [440]*440prior medical opinion on his competency to stand trial are all relevant in determining whether there existed “good cause for a hearing” and even that one of these factors alone may be sufficient. Pate v. Robinson (1966), 383 U. S. 375, and Drope v. Missouri (1975), 420 U. S. 162, at 180.

This court is observant of the court’s remarks in Drope, supra, at page 181, when it stated:

“Even when a defendant is competent at the commencement of his trial, a trial court must always be alert to circumstances suggesting a chance that would render the accused unable to meet the standards of competence to stand trial.”

In State v. Jemison (1968), 14 Ohio St. 2d 47, this court did not allow an additional hearing, pursuant to R. C. 2945.37, upon a subsequent suggestion of competency to stand trial when the court was not informed as to how the defendant had become insane since a prior determination.

In Jemison, supra, the court had, pursuant to R. C. 2945.40, an initial determination that defendant was competent to stand trial. There was a substantial delay of several months between the initial examination of competency and the trial itself. Defense counsel did submit a letter from a psychiatrist as evidence that defendant had become insane since the initial competency determination.

Even under the old law, which, as noted herein, mandated a hearing without differentiating between suggestions of competency made before or after trial, this court inspected the psychiatrist’s letter and determined that it disclosed no positive suggestion that defendant had become insane subsequent to the initial determination of sanity. This court concluded by not allowing the second hearing. In paragraph one of the syllabus, we stated that:

“Where a defendant in a criminal case has interposed a defense of insanity, has been committed to the Lima State Hospital pursuant to Section 2945.40 of the Revised Code, and there is found capable of understanding the nature of the charges against him and of counseling in his own defense, a subsequent suggestion of insanity under Section 2945.37 of the Revised Code, which does not inform the court that defendant has become insane since the prior determination of sanity was made, does not require the court to make a second exami[441]*441nation into the question of the sanity of such defendant. (Evans v. State, 123 Ohio St. 132, and State v. Smith, 123 Ohio St. 237, distinguished.)”

Our task herein is ultimately to determine whether appellee received a fair trial and whether, under the facts in this cause, appellee met the requisite standard of “good cause shown,” pursuant to the present R. C. 2945.37, which would warrant a hearing on the issue of competency to stand trial.

The record clearly indicates that a hearing concerning competency to stand trial was held approximately three months before trial, whereupon the evidence submitted, which included psychiatric reports, resulted in the decision that appellee was competent to stand trial. Thus, all prior medical reports clearly indicated that appellee was competent to stand trial.

The record further discloses that, except for one minor, isolated instance, appellee had not displayed any ludicrous or irrational behavior at trial which would suggest to the court that an additional hearing was necessary.1

The record is devoid of any objective indications as to how and to what extent appellee’s mental condition has changed.

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Cite This Page — Counsel Stack

Bluebook (online)
424 N.E.2d 317, 67 Ohio St. 2d 437, 21 Ohio Op. 3d 273, 1981 Ohio LEXIS 600, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-chapin-ohio-1981.