State v. Counts

2024 Ohio 1362
CourtOhio Court of Appeals
DecidedApril 11, 2024
Docket112715 & 112775
StatusPublished

This text of 2024 Ohio 1362 (State v. Counts) 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. Counts, 2024 Ohio 1362 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Counts, 2024-Ohio-1362.] COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiffs-Appellants, : Nos. 112715 and 112775 v. :

KAYLYNN COUNTS, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND REMANDED RELEASED AND JOURNALIZED: April 11, 2024

Criminal Appeal from the Cuyahoga County Common Pleas Court Case No. CR-18-634510-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Chadwick Cleveland and Anthony T. Miranda, Assistant Prosecuting Attorneys, for appellant the state of Ohio.

Elizabeth A. Well, Ohio Crime Victim Justice Center, for alleged victims-appellants.

Russell S. Bensing, for appellee Kaylynn Counts.

Cullen Sweeney, Cuyahoga County Public Defender, and John T. Martin and Erika B. Cunliffe, Assistant Public Defenders, amicus curiae urging affirmance. ANITA LASTER MAYS, J.:

{¶1} Plaintiffs-appellants, state of Ohio (“the state”) and the alleged victims

(“victims”) in this case appeal the trial court’s decision dismissing the case against

defendant-appellee, Kaylynn Counts (“Counts”). We reverse the trial court’s

decision and remand for further proceedings consistent with this opinion.1

I. Facts and Procedural History

{¶2} The facts of this case are as follows:

[I]n the fall of 2018, Kaylynn Counts, a college student, was staying in the home of a family member, Lavon Thomas, a 72-year-old woman and the mother of Felicia Kelly. On November 9, 2018, Thomas and Kelly told Counts to leave the home. It is alleged that in the ensuing altercation Counts assaulted Thomas and stabbed Kelly. Counts has maintained that she acted in self-defense.

State ex rel. Thomas v. McGinty, 8th Dist. Cuyahoga No. 108633, 2019-Ohio-

5129, 137 N.E.3d 1278, ¶ 2 (“McGinty I”).

{¶3} Counts was indicted on December 3, 2018, for attempted murder and

felonious assault. On April 1, 2019, Counts filed a motion for “Criminal Rule 16,

Entry upon Land for Inspection and Photograph,” seeking an order from the trial

court to access the victims’ home. In the motion, Counts states that her ability to

inspect and photograph the home is material to the preparation of her defense.

1 8th Dist. Cuyahoga Nos. 112715 and 112775 were consolidated by this court on January

30, 2024, only for disposition. {¶4} On May 16, 2019, the trial court held a hearing on the motion. The trial

court granted the motion and stated in its journal entry, in part:

The court finds that the defendant’s motion for Criminal Rule 16 entry upon land for inspection and photograph is granted. The court orders: The parties communicate to provide 3 available days with a specific time to allow state to confer with homeowner. The state will indicate to defense counsel the date for discovery. The court orders that bailiff shall be the court representative and be present at all times while the defendant, defense counsel, and their experts are within the residence. At all times, the defendant, defense counsel, and their expert shall be within the view of the bailiff. The court orders that a sheriff’s deputy shall assist bailiff in this procedure. The victim shall not be in the residence once the discovery process commences. The court further orders that Cleveland Police Department and County Prosecutor personell [sic] may be present, but may not be within the residence when the discovery is ongoing.

Journal Entry No. 108790054 (May 20, 2019).

{¶5} On May 21, 2019, the state filed a motion for leave to appeal. This court

denied the motion and dismissed the appeal. The Supreme Court of Ohio also

declined to accept jurisdiction over the appeal. On May 31, 2019, the victims in the

case filed a petition for a writ of prohibition against the trial court judge. In

McGinty I, this court dismissed the petition and granted the trial court’s motion to

dismiss. Id. at ¶ 1.

{¶6} The decision was appealed to the Supreme Court, which affirmed this

court’s decision and stated:

Although crime victims have a right under the Ohio Constitution to judicial review of discovery orders affecting their Marsy’s Law rights, a writ of prohibition is not the correct mechanism to challenge Judge McGinty’s order. We therefore affirm the Eighth District’s judgment. State ex rel. Thomas v. McGinty, 164 Ohio St.3d 167, 2020-Ohio-5452, 172

N.E.3d 824, ¶ 2 (“McGinty II”).

{¶7} The Supreme Court stated that the trial court’s order failed to order the

appellants to provide access to their home. Id. at ¶ 22. Additionally, the Supreme

Court held that “a writ of prohibition remains an inappropriate vehicle for a

nonparty to a criminal proceeding to challenge a discovery order.” Id. at ¶ 23.

{¶8} On February 2, 2021, the state filed a notice of discovery in connection

with the trial court’s May 20, 2019 discovery order. The state explained to the court

that after conferring with the victims’ counsel, neither victim would agree to a

defense inspection of the residence where the incident took place.

{¶9} The trial court held a hearing on July 13, 2021, in response to the notice

of discovery. At the hearing, it was discussed whether the victims were willing to

provide a date to open their home pursuant to the court order. Tr. 50. The victims

indicated that they were unwilling “to do so.” Tr. 51. The victims expressed to the

court that they were uncomfortable with Counts coming back to the home. Tr. 53.

The court inquired if the victims would allow Counts’s attorneys, without Counts,

to inspect the home. They agreed, as long as Counts was not allowed in the home.

They also expressed to the court that they would not be comfortable with allowing

the court staff or Counts’s attorneys in the home without one of their family

members present. [Cite as State v. Counts, 2024-Ohio-1362.] {¶10} Counts’s counsel explained to the court that there were two areas of

disagreement. First, they insisted that Counts be able to come to the home and

explain what took place. Second, they refused to agree to a family member being

present because they would not be free to have any discussions.

{¶11} The family rejected this, but asked the court if Counts’s counsel could

Facetime Counts while they were in the home, so that she would not be physically

present in their home. The trial court stated that it was a “wonderful suggestion,”

however Counts’s trial counsel would not agree. The trial court stated:

Okay. Here’s my thought process. We’re sitting here. The order was back on May 20, 2019. We’ve had a little bit of COVID. We’ve had a couple trips to the court of appeals, two trips to the supreme court. The case is back here. We’re still on Zoom with the majority of the parties. If I put an order on ordering the inspection – I’m just talking outloud [sic] right now – it sounds like the victims under Marsy’s Law are going to appeal, and then we’ll be back here in two more years. Anybody disagree with what I just said?

Tr. 63.

{¶12} On November 19, 2021, the trial court issued the following decision:

The trial court is the gate-keeper of the discovery process as governed by Crim.R. 16, and has the power to mandate reasonable discovery orders. Therefore, Defendant’s Motion for Criminal Rule 16 Entry Upon Land for Inspection and Photograph is granted.

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2024 Ohio 1362, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-counts-ohioctapp-2024.