State v. D'Andrea

Ohio Court of Appeals·Decided June 15, 2026·No. 15-25-10·Published

Opinion

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT

VAN WERT COUNTY

STATE OF OHIO, CASE NO. 15-25-10

PLAINTIFF-APPELLEE,

v.

GUY ALAN D'ANDREA, OPINION AND JUDGMENT ENTRY

DEFENDANT-APPELLANT.

Appeal from Van Wert County Common Pleas Court Trial Court No. CR-24-11-144

Judgment Affirmed

Date of Decision: June 15, 2026

APPEARANCES:

Kenneth J. Rexford for Appellant Morgan A. Jackson for Appellee

WALDICK, J.

{¶1} Defendant-appellant, Guy A. D’Andrea (“D’Andrea”), brings this appeal from the November 24, 2025 judgment of the Van Wert County Common Pleas Court sentencing him to prison after D’Andrea was convicted by a jury of Endangering Children in violation of R.C. 2919.22(B)(1), a second degree felony. For the reasons that follow, we affirm the judgment of the trial court.

Background

{¶2} On November 7, 2024, D’Andrea was indicted for Endangering Children in violation of R.C. 2919.22(B)(1), a second degree felony, and Endangering Children in violation of R.C. 2919.22(B)(3), a second degree felony. It was alleged that D’Andrea kicked the groin-area of his 11-year-old foster-child, N.K., causing serious physical harm. D’Andrea pled not guilty to the charges.

{¶3} D’Andrea proceeded to a jury trial, which was held October 20-23, 2025. The jury determined that D’Andrea was guilty of Endangering Children in violation of R.C. 2919.22(B)(1), but not guilty of the alternative allegation of Endangering Children in violation of R.C. 2919.22(B)(3). On November 24, 2025, D’Andrea was sentenced to serve an indefinite prison term of four to six years. D’Andrea now brings the instant appeal, asserting the following assignments of error for our review.

First Assignment of Error

The failure of the Trial Court to properly and adequately record all of the proceedings at trial violated Mr. D’Andrea’s right to due process, assured to him by the Ohio Constitution and the United States Constitution.

Second Assignment of Error The Trial Court erred by allowing N.K. to testify.

Third Assignment of Error

The Trial Court erred in finding Mr. D’Andrea guilty because the conviction was against the manifest weight of the evidence.

{¶4} For ease of discussion, we elect to address the assignments of error out of the order in which they were raised.

Second Assignment of Error

{¶5} In his second assignment of error, D’Andrea argues that the trial court erred by determining that N.K. was competent to testify.

Standard of Review

{¶6} A trial court’s determination of whether a child is competent to testify is reviewed under an abuse of discretion standard. See State v. Spencer, 2025-Ohio- 3268, ¶ 16 (7th Dist.); State v. Maxwell, 2014-Ohio-1019, ¶ 100 (addressing a prior version of Evid.R. 601). A trial court abuses its discretion when its determination is

arbitrary, unreasonable, or unconscionable. Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983).

Relevant Authority

{¶7} Evidence Rule 601(A) states that “Every person is competent to be a witness except as otherwise provided in these rules.”1 Evidence Rule 601(B) then provides guidelines for the disqualification of witnesses. It reads, in pertinent part,

A person is disqualified to testify as a witness when the court determines that the person is any of the following:

(1) Incapable of expressing himself or herself concerning the matter as to be understood, either directly or through interpretation by one who can understand him or her;

(2) Incapable of understanding the duty of a witness to tell the truth[.]

{¶8} Further guidance regarding the competency of witnesses is provided in R.C. 2317.01, which reads, “All persons are competent witnesses except those of unsound mind and children under ten years of age who appear incapable of receiving just impressions of the facts and transactions respecting which they are examined, or of relating them truly.” Notably, competency of a child to testify is determined

1 A prior version of Evidence Rule 601 indicated that “children under ten years of age, who appear incapable of receiving just impression of the facts and transactions respecting which they are examined, or of relating them truly” were not competent to testify. The age cutoff has been removed from Evid.R. 601(A), but not from R.C. 2317.01.

as of the time of trial, not at the time the crime allegedly occurred. State v. Clark, 1994-Ohio-43.

{¶9} In making a competency determination, the Supreme Court of Ohio has directed trial courts to consider the following factors, particularly when evaluating a child under ten years of age: (1) the child’s ability to receive accurate impressions of fact or to observe acts about which he or she will testify; (2) the child’s ability to recollect those impressions or observations; (3) the child’s ability to communicate what was observed; (4) the child’s understanding of truth and falsity; and (5) the child’s appreciation of his or her responsibility to be truthful. State v. Frazier, 61 Ohio St.3d 247, 251 (1991).

Analysis

{¶10} N.K., the victim in this matter, was born in December of 2012. N.K.

is autistic and has cerebral palsy. N.K. alleged that she was injured by D’Andrea in early August of 2024, making her 11 years old at the time of the incident.

{¶11} On February 21, 2025, D’Andrea filed a motion to determine N.K.’s competency as a witness. Under Evid.R. 601 and R.C. 2317.01, when an issue arises as to the competency of a child to testify, “the responsibility of the trial judge is to determine through questioning whether the child of tender years is capable of receiving just impressions of facts and events and to accurately relate them.” State v. Frazier, 61 Ohio St.3d 247, 251 (1991). Importantly, under the legal authority

cited herein, we must “start with the presumption that all persons are competent to testify, even children[,]” particularly if the child is over 10 years old. State v. Spencer, 2025-Ohio-3268, ¶ 17 (7th Dist.).

{¶12} A hearing on N.K.’s competency as a witness was held on April 10, 2025. The trial court addressed N.K. directly and asked her a series of questions. N.K. provided her first and last name and testified that she was 12 years old, but she initially provided her birth year as 2002 instead of 2012. The trial judge spoke with N.K. further on the matter but N.K. struggled with the math.

{¶13} When asked, N.K. provided the school she attended, the grade she was in, her teachers, and her favorite activity. N.K. indicated she had four sisters, though she only regularly saw one of the sisters. N.K. also knew the name of the person her sister was placed with.

{¶14} N.K. was asked if she knew what it meant to tell the truth and she said it was the “opposite of lying.” The trial court provided an example, asking if it would be a lie if he said there were twenty people sitting in the audience. N.K. indicated it would be a lie because there were not twenty people in the audience.

{¶15} Nevertheless, N.K. did express some uncertainty regarding the difference between the truth and a lie, so the trial court continued to question her. N.K. indicated that it was good to tell the truth and she was going to tell the truth because if she did not she would get in “big trouble.”

{¶16} The trial court then further inquired into N.K.’s memory, asking her about summer activities. N.K. indicated she enjoyed swimming at a “splash pad,” and she named some of her friends from summer camp. After some further discussion, the hearing concluded.

{¶17} On April 11, 2025, the trial court issued a written decision finding N.K. competent to testify in this case. N.K. did, in fact, testify at trial against D’Andrea.

{¶18} D’Andrea argues that the trial court abused its discretion by determining that N.K. was competent to testify. He argues that N.K. was known to be autistic, prone to self-harm, and confused about her own birth date. He argues that N.K. did not adequately demonstrate she understood the difference between the truth and a lie and that her responses at times were “bizarre.”

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