State v. Cochran

2024 Ohio 1997
CourtOhio Court of Appeals
DecidedMay 23, 2024
Docket23AP-258
StatusPublished
Cited by4 cases

This text of 2024 Ohio 1997 (State v. Cochran) 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. Cochran, 2024 Ohio 1997 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Cochran, 2024-Ohio-1997.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State of Ohio, :

Plaintiff-Appellee, : No. 23AP-258 (C.P.C. No. 2oCR-238) v. : (REGULAR CALENDAR) Douglas B. Cochran, :

Defendant-Appellant. :

D E C I S I O N

Rendered on May 23, 2024

On brief: G. Gary Tyack, Prosecuting Attorney, and Michael A. Walsh, for appellee. Argued: Michael A. Walsh.

On brief: Campbell Law, LLC, and April F. Campbell, for appellant. Argued: April F. Campbell.

APPEAL from the Franklin County Court of Common Pleas

LUPER SCHUSTER, J. {¶ 1} Defendant-appellant, Douglas B. Cochran, appeals from a judgment of the Franklin County Court of Common Pleas convicting him, following his guilty pleas, of three counts of gross sexual imposition and one count of importuning. The trial court imposed a total prison sentence of five years for these offenses. For the following reasons, we affirm. I. Procedural Background {¶ 2} In January 2020, the Franklin County Grand Jury indicted Cochran on three counts of gross sexual imposition, in violation of R.C. 2907.05, each third-degree felonies, and one count of importuning, in violation of R.C. 2907.07, also a third-degree felony. The indictment was based on alleged criminal conduct involving a minor occurring between August 2010 and August 2013. Cochran initially pled not guilty. In February 2023, No. 23AP-258 2

however, Cochran changed his plea to guilty on all four counts. The trial court imposed sentences of 5 years in prison on each of the gross sexual imposition counts, and 36 months in prison on the importuning count. The trial court ordered these sentences be served concurrently, for a total of 5 years of incarceration. {¶ 3} Cochran timely appeals. II. Assignments of Error {¶ 4} Cochran assigns the following two assignments of error for our review: [I.] Cochran’s sentences should be reversed because trial counsel was ineffective with resulting prejudice:

A. He failed to file a not guilty by reason of insanity plea on Cochran’s behalf.

B. He did not review medical records that documented a severe mental defect at the time the offenses occurred.

C. He failed to submit Cochran’s medical records, as well as the forensic psychiatrist’s evaluation in support of that plea on Cochran’s behalf.

[II.] Cochran’s sentences should be reversed, because there is clear and convincing evidence that the record does not support the trial court’s imposition of the maximum sentence, and his sentence is also contrary to law.

III. Discussion {¶ 5} In his first assignment of error, Cochran argues he received ineffective assistance of counsel. This assignment of error lacks merit. {¶ 6} In order to prevail on a claim of ineffective assistance of counsel, Cochran must satisfy a two-prong test. First, he must demonstrate that his counsel’s performance was deficient. Strickland v. Washington, 466 U.S. 668, 687 (1984). This first prong requires Cochran to show that his counsel committed errors which were “so serious that counsel was not functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment.” Id. If Cochran can so demonstrate, he must then establish that he was prejudiced by the deficient performance. Id. To show prejudice, Cochran must establish there is a reasonable probability that, but for his counsel’s errors, the results of the trial No. 23AP-258 3

would have been different. A “reasonable probability” is one sufficient to undermine confidence in the outcome of the trial. Id. at 694. In considering claims of ineffective assistance of counsel, courts review these claims with a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance. State v. Conway, 109 Ohio St.3d 412, 2006-Ohio-2815, ¶ 101. And a court is not required “to approach the inquiry in the same order or even to address both components of the inquiry if the defendant makes an insufficient showing on one. In particular, a court need not determine whether counsel’s performance was deficient before examining the prejudice suffered by the defendant as a result of the alleged deficiencies.” Strickland at 697. {¶ 7} Cochran contends his trial counsel was ineffective in: (1) not filing a not guilty by reason of insanity (“NGRI”) plea on his behalf; (2) not reviewing medical records documenting his severe mental defect at the time he committed the offenses; and (3) not submitting his medical records and forensic psychiatrist’s evaluation in support of an NGRI plea. Cochran argues these deficiencies prejudiced him and therefore he met both prongs of the Strickland test. {¶ 8} Each of the deficiencies alleged by Cochran relates to the affirmative defense of insanity, which must be proven by a preponderance of the evidence. State v. Taylor, 98 Ohio St.3d 27, 2002-Ohio-7017, ¶ 64; R.C. 2901.05(A). The defendant must persuade the trier of fact that “at the time of the commission of the offense, the [defendant] did not know, as a result of a severe mental disease or defect, the wrongfulness of the [defendant’s] acts.” R.C. 2901.01(A)(14). Conversely, a defendant cannot avoid criminal responsibility if the defendant “knows his or her conduct violates the law and commonly held notions of morality.” State v. Jennings, 10th Dist. No. 05AP-1051, 2006-Ohio-3704, ¶ 22. This means, to prove insanity, demonstrating a mental defect is not enough; the defendant must also show an inability to understand right from wrong. {¶ 9} Here, Cochran asserts the record contains evidence that he did not know the wrongfulness of his conduct because of a severe mental disease or defect, and that, based on this information, his trial counsel should have pursued this affirmative defense on his behalf. In support, he cites information in the sentencing memorandum indicating he had a brain tumor the size of a fist removed in 2009, and that he suffered from multiple cranial infections in the years following the tumor removal, which overlapped the years of his No. 23AP-258 4

criminal conduct. The sentencing memorandum requested lenience based on Cochran’s significant medical difficulties and its impact on him. The sentencing memorandum also described the observations of a psychologist1 who interviewed Cochran and reviewed his medical records. The memorandum indicates the psychologist described the impact of a brain tumor and related treatment on a person’s brain functioning, including neurological, cognitive, and psychiatric effects, such as personality and behavioral changes. The psychologist opined that Cochran’s behavioral changes described by family members, such as cognitive and emotional problems, were consistent with scientific research regarding brain tumors and their treatment. Notably absent from the sentencing memorandum, however, is any indication that Cochran’s medical condition negated or even altered his understanding of right from wrong. Similarly, at the sentencing hearing, Cochran’s counsel reiterated that Cochran’s criminal actions were an anomaly, and he requested the court to consider this and the medical circumstance as mitigating factors for the purpose of sentencing. In support, his counsel noted the psychologist opined that “it simply cannot be ruled out that the removal of this gigantic brain tumor was the impetus for his actions.” (Mar. 30, 2023 Tr. at 17.) In his statement to the sentencing court, Cochran acknowledged the harm he caused, but he also referenced his medical condition and its impact on his ability to recall what occurred. At the hearing, neither Cochran nor his counsel indicated his mental ability to process right from wrong was ever compromised.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Kendrick
2025 Ohio 5739 (Ohio Court of Appeals, 2025)
State v. Burson
2025 Ohio 499 (Ohio Court of Appeals, 2025)
State v. Smith
2024 Ohio 5613 (Ohio Court of Appeals, 2024)
State v. Garcia
2024 Ohio 5612 (Ohio Court of Appeals, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 1997, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cochran-ohioctapp-2024.