State v. Cunningham

2024 Ohio 1739, 242 N.E.3d 887
Ohio Court of Appeals·Decided May 6, 2024·No. 2023-P-0084·Published·Cited by 1 cases

Opinion

[Cite as State v. Cunningham, 2024-Ohio-1739.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT PORTAGE COUNTY

STATE OF OHIO, CASE NO. 2023-P-0084

Plaintiff-Appellee, Criminal Appeal from the - vs - Court of Common Pleas

CASEY A. CUNNINGHAM, Trial Court No. 2023 CR 00536 Defendant-Appellant.

OPINION

Decided: May 6, 2024 Judgment: Affirmed

Victor V. Vigluicci, Portage County Prosecutor, Kristina K. Reilly, Assistant Prosecutor, and Pamela J. Holder, Assistant Prosecutor, 241 South Chestnut Street, Ravenna, OH 44266 (For Plaintiff-Appellee).

Donald K. Pond, Jr., 567 East Turkeyfoot Lake Road, Suite 107, Akron, OH 44319 (For Defendant-Appellant).

JOHN J. EKLUND, J.

{¶1} Appellant, Casey Cunningham, appeals from his conviction for Violating a

Protection Order, a fifth-degree felony in violation of R.C. 2919.27. Appellant raises one

assignment of error, arguing the trial court abused its discretion by failing to sua sponte

conduct an inquiry to determine whether appellant was competent to stand trial after what

appellate counsel describes as appellant’s “tangential, disjointed, paranoid, erratic, and

manic” trial testimony. {¶2} Having reviewed the record and the applicable caselaw, we find appellant’s

assignment of error is without merit. The transcripts of the trial and sentencing hearing

demonstrate that appellant consistently engaged with the trial court and with his attorneys

cogently and appropriately. Although appellant’s testimony was peculiar and aptly

described as “paranoid” at times, even an emotionally disturbed individual can be capable

of understanding the nature of the charges against him and assisting in his own defense.

Appellant’s trial counsel and the trial court were in the best position to observe him and

raise this issue below. A competency question is one that is often difficult to address and

one with no definite signs which would “invariably indicate the need for further inquiry.”

Drope v. Missouri, 420 U.S. 162, 180, 95 S.Ct. 896, 43 L.Ed.2d 103 (1975).

{¶3} Appellant’s interactions available to us in the record tend to demonstrate

that appellant had the present ability to understand the nature and objective of the

proceedings and to assist in his own defense. The record does not support finding that

the trial court abused its discretion in failing to sua sponte address appellant’s

competency to stand trial.

{¶4} Therefore, we affirm the judgment of the Portage County Court of Common

Pleas.

Substantive and Procedural History

{¶5} On May 18, 2023, appellant was charged with two counts of Violating a

Protection Order, fifth-degree felonies in violation of R.C. 2919.27.

{¶6} On June 5, 2023, appellant entered a plea of not guilty and the matter was

set for trial.

Case No. 2023-P-0084 {¶7} Jury trial commenced on July 25, 2023. At trial, appellant was represented

by two court appointed attorneys. The State moved to dismiss Count 2 and to proceed to

trial only on Count 1. In addition, the parties stipulated that appellant had been served

with a valid protection order that was in effect on the date of the offense. The protection

order was also entered into evidence as an exhibit.

{¶8} Alexis Culbert testified that she and appellant were in a relationship

between August 30, 2020 to January 30, 2022. Culbert decided to end the relationship

and moved out. She said appellant continued to contact her and she felt threatened, so

she obtained a protection order. Culbert said that there was a prior incident where

appellant contacted her, and he was convicted for Violating a Protection Order. The initial

protection order expired, and Culbert obtained another protection order active from March

27, 2023, until February 22, 2028.

{¶9} On April 20, Culbert attended a local music festival in Portage County. She

said the festival included a campsite, where she stayed with her boyfriend, Jonathan

Cousins, her sister, and some friends.

{¶10} Culbert said that after nightfall, she and Cousins were looking for a friend at

the festival. While they were doing this, appellant tapped Culbert on the shoulder and

said, “Hello, friend.” Culbert said she panicked and grabbed Cousins, pulled him away,

and told him that appellant had approached her.

{¶11} Jonathan Cousins testified that he had never met appellant but said that he

knew about Culbert’s relationship with him and the protection order. He said he was with

Culbert and saw a man come up to her and tap her on the shoulder. He then said Culbert

grabbed him with “fear in her eyes” and said that appellant “just came up to me.”

Case No. 2023-P-0084 {¶12} After appellant approached Culbert, Culbert and Cousins talked to the

festival security staff about the incident.

{¶13} Steven Liller worked as security at the music festival. He said when security

approached appellant to ask him to leave the festival, appellant became belligerent and

said the protection order was Culbert’s problem and that they should “make her leave.”

Liller said appellant began to go on a tirade, but the festival promoter felt it would be better

not to further aggravate appellant or cause a physical altercation, so security left him

alone for the time being.

{¶14} Leah Morosky testified she was dating appellant at the time of the festival.

She said the two attended the festival together. She said she was aware that Culbert had

a protection order against appellant and that Culbert might also be at the festival. Once

at the festival, she said the festival facilitator approached them and said appellant could

not attend because of the protection order. However, after saying they would keep to

themselves, the facilitator agreed to let them attend.

{¶15} She said she and appellant were listening to a performance and saw a

woman she recognized from a photo to be Culbert “quite a little ways away from us.” She

said that appellant got up from the table they were at, walked “straight towards” Culbert,

and spoke to her. Morosky said appellant was “bee-lining it for her.”

{¶16} On April 22, 2023, security again encountered appellant at the festival and,

along with Portage County Sheriff’s Deputies, removed appellant from the festival

grounds.

{¶17} After the State rested its case, the Court reminded appellant of his

constitutional right to not testify and the trial court asked if appellant “had sufficient time

Case No. 2023-P-0084 to talk to your lawyers about this?” Appellant said that he felt “rushed” and discussed his

concerns on the record. Appellant asked to defer the decision to testify until the next day.

Appellant’s trial counsel similarly asked to allow appellant to have an opportunity to think

about testifying until the morning, and the trial court agreed.

{¶18} The next morning, appellant informed the trial court that he wanted to testify

and advised the court that he wanted to fire Attorney Ellis, one of his two trial attorneys.

The trial court did not entertain firing counsel mid-trial, in part because appellant’s counsel

had already prepared for trial under the assumption of going to trial with co-counsel

participation. Appellant responded “I carry a concern of a predisposition of personal –

what’s the word I’m looking for? [Attorney Elliss is] not quite a fan of my character and

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State v. Cunningham, 2024 Ohio 1739, 242 N.E.3d 887 (Ohio Ct. App. 2024).

2024 Ohio 1739 (State v. Cunningham) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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