State v. D'Andrea

CourtOhio Court of Appeals
DecidedJune 15, 2026
Docket15-25-10
StatusPublished

This text of State v. D'Andrea (State v. D'Andrea) 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. D'Andrea, (Ohio Ct. App. 2026).

Opinion

[Cite as State v. D'Andrea, 2026-Ohio-2247.]

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 Case No. 15-25-10

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.

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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.

{¶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

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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.

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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

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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

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Related

State v. Palmer
1997 Ohio 312 (Ohio Supreme Court, 1997)
State v. Hunter
2011 Ohio 6524 (Ohio Supreme Court, 2011)
State v. Maxwell
2014 Ohio 1019 (Ohio Supreme Court, 2014)
State v. Haller
2012 Ohio 5233 (Ohio Court of Appeals, 2012)
State v. McClusky, Unpublished Decision (1-9-2004)
2004 Ohio 85 (Ohio Court of Appeals, 2004)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
State v. Frazier
574 N.E.2d 483 (Ohio Supreme Court, 1991)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)
State v. Spencer
2025 Ohio 3268 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
State v. D'Andrea, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-dandrea-ohioctapp-2026.