State v. Davis

2026 Ohio 52
Ohio Court of Appeals·Decided January 9, 2026·No. 2025-CA-23·Published

Opinion

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MIAMI COUNTY

STATE OF OHIO :

: C.A. No. 2025-CA-23

Appellee :

: Trial Court Case No. 25 CR 5 v. :

: (Criminal Appeal from Common Pleas DANIEL H. DAVIS, JR. : Court)

:

Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on January 9, 2026, the judgment of the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately serve notice of this judgment upon all parties and make a note in the docket of the service. Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

EPLEY, P.J., and LEWIS, J., concur.

OPINION

MIAMI C.A. No. 2025-CA-23

ALANA VAN GUNDY, Attorney for Appellant MATTHEW C. JOSEPH, Attorney for Appellee

TUCKER, J.

{¶ 1} Daniel H. Davis, Jr. appeals from his conviction following a guilty plea to one count of aggravated murder with a firearm specification.

{¶ 2} Davis alleges ineffective assistance of counsel based on his attorney’s stipulation to a competency examination and failure to request a second opinion. He also argues that the trial court erred in finding that he had no mental-health issues and in failing to consider his mental-health history at sentencing. Finally, he contends the trial court erred in sentencing him to 30 years to life in prison without considering his mental-health issues.

{¶ 3} For the reasons set forth below, we find Davis’s arguments to be unpersuasive and affirm the trial court’s judgment.

I. Background

{¶ 4} A grand jury indicted Davis on one count of aggravated murder, three counts of murder, and two counts of felonious assault with accompanying firearm specifications. The charges involved Davis driving to his father’s house, retrieving a handgun from inside the house, meeting his father in the garage, and shooting his father twice. After he pled not guilty by reason of insanity, the trial court ordered a mental examination to evaluate his competence to stand trial and his mental condition at the time of the charged offenses. The examination was performed by a licensed psychologist who submitted a report finding Davis competent to stand trial and legally sane when he allegedly committed the offenses. The State stipulated to the psychologist’s findings. Defense counsel stipulated to the report’s

admissibility and “ha[d] nothing further as to competency or sanity.” Davis then withdrew his insanity plea, and the trial court found him competent to stand trial. He later pled guilty to aggravated murder with a firearm specification in exchange for dismissal of all other charges and specifications. In his written plea, Davis acknowledged that he was not suffering from any mental condition that would interfere with his ability to make informed decisions on his own behalf. He also acknowledged being satisfied with his attorney’s advice and competence.

{¶ 5} During his Crim.R. 11 plea hearing, Davis denied being on any prescription medications that would affect his ability to understand what was happening. He likewise denied being diagnosed with any mental illness that would affect his comprehension. Defense counsel opined that Davis understood what he was doing by pleading guilty. Davis responded appropriately to all questions, and the trial court found that he was alert and capable of participating in the plea hearing. At the conclusion of the hearing, the trial court accepted the guilty plea and made a finding of guilt.

{¶ 6} The trial court then held an evidentiary hearing prior to sentencing. It heard testimony from Davis, his mother, and two law-enforcement officers. It later imposed a sentence of 30 years to life in prison for aggravated murder plus a three-year consecutive prison term for the firearm specification. Davis timely appealed, advancing three assignments of error.

II. Analysis

{¶ 7} The first assignment of error states:

Mr. Davis Jr. was denied the effective assistance of counsel when trial counsel stipulated to the competency evaluation and failed to request a second evaluation, resulting in the trial court’s acceptance of a plea

without adequately determining Mr. Davis Jr.’s competency in violation of the Sixth and Fourteenth Amendments to the United States Constitution and Article I, Section 10 of the Ohio Constitution.

{¶ 8} Davis contends his trial counsel provided ineffective assistance by stipulating to the competency evaluation and failing to request a second opinion. He claims the evaluation report was deficient and objectionable because it (1) invalidated the results of a test that had shown “an extremely elevated number of items in the psychopathological direction” and (2) stated that Davis had no history of medication or developmental disability, whereas his mother testified prior to sentencing that he had been prescribed a dozen medications and had been on an IEP plan in high school. Davis asserts that his attorney’s ineffective assistance resulted in the trial court accepting his guilty plea without assurance that he could understand the proceedings, thereby calling into question the knowing, intelligent, and voluntary nature of his plea.

{¶ 9} We review alleged instances of ineffective assistance of counsel under the two-

part analysis found in Strickland v. Washington, 466 U.S. 668 (1984), which the Ohio Supreme Court adopted in State v. Bradley, 42 Ohio St.3d 136 (1989). To prevail on an ineffective-assistance claim, a defendant must show trial counsel rendered deficient performance and that counsel’s deficient performance prejudiced him. Strickland at paragraph two of the syllabus; Bradley at paragraph two of the syllabus.

{¶ 10} Courts assess deficient performance by asking whether counsel’s conduct “fell below an objective standard of reasonableness.” Strickland at 688. When making this determination, counsel’s conduct must be judged based on “the facts of the particular case, viewed as of the time of counsel’s conduct.” Id. at 690. Only when counsel’s errors were “so serious that counsel was not functioning as the ‘counsel’ guaranteed the defendant by the

Sixth Amendment” has counsel engaged in deficient performance. Id. at 687. To establish prejudice, “[t]he defendant must show that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 694. This requires the errors to be so significant as to “undermine confidence in the outcome.” Id. The failure to make a showing of either prong of the Strickland inquiry is fatal to a claim of ineffective assistance. Id. at 692.

{¶ 11} A guilty plea waives ineffective assistance of counsel unless counsel’s deficient performance negated the knowing, intelligent, and voluntary nature of the plea. State v. Barnett, 73 Ohio App.3d 244, 249 (2d Dist. 1991). In the present case, waiver does not apply because Davis’s ineffective-assistance argument challenges his competence to stand trial and, by extension, his competence to enter a guilty plea. See, e.g., State v. Littler, 2023-Ohio-4759, ¶ 19 (4th Dist.) (recognizing that the competency standards for entering a plea and standing trial are the same).

{¶ 12} Under Ohio law, a defendant is competent to stand trial unless he is incapable of understanding the nature and objective of the proceedings or of assisting in his own defense. R.C. 2945.37(G). The question is whether a defendant “has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding—and whether he has a rational as well as factual understanding of the proceedings against him.” State v. Lawson, 2021-Ohio-3566, ¶ 49, quoting Dusky v. United States, 362 U.S. 402, 402 (1960).

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