State v. Deloney

2017 Ohio 9282
CourtOhio Court of Appeals
DecidedDecember 29, 2017
DocketC-150619
StatusPublished
Cited by4 cases

This text of 2017 Ohio 9282 (State v. Deloney) 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. Deloney, 2017 Ohio 9282 (Ohio Ct. App. 2017).

Opinion

[Cite as State v. Deloney, 2017-Ohio-9282.] IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-150619 TRIAL NO. B-1303726 Plaintiff-Appellant, : O P I N I O N. vs. :

JOHN DELONEY, :

Defendant-Appellee. :

Criminal Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Reversed and Cause Remanded

Date of Judgment Entry on Appeal: December 29, 2017

Joseph T. Deters, Hamilton County Prosecuting Attorney, and Ronald W. Springman, Assistant Prosecuting Attorney, for Plaintiff-Appellant,

Faulkner & Tepe, LLP, A. Norman Aubin and Wilkes R. Ellsworth, for Defendant- Appellee. O HIO F IRST D ISTRICT C OURT OF A PPEALS

M OCK , Presiding Judge.

{¶1} On June 21, 2013, defendant-appellee John Deloney was indicted on

one count of aggravated murder with a death-penalty specification and one count of

aggravated robbery with a gun specification. The case proceeded for nearly two years

while the trial court attempted to determine if Deloney was eligible for the death

penalty because of the claim asserted by counsel that he was mentally retarded. The

trial court determined that subjecting Deloney to the death penalty would constitute

cruel and unusual punishment. See Atkins v. Virginia, 536 U.S. 304, 122 S.Ct. 2242,

153 L.Ed.2d 335 (2002); State v. Lott, 97 Ohio St.3d 303, 2002-Ohio-6625, 779

N.E.2d 1011. The state now appeals, asserting one assignment of error.

{¶2} From the time that counsel for Deloney filed the motion pursuant to

Atkins and Lott claiming that Deloney was not eligible for the death penalty, Deloney

and his family refused to cooperate in the prosecution of the motion. In its entry, the

trial court spent several pages examining in detail the struggles of numerous

attorneys and medical professionals, and its own efforts, to convince Deloney to

submit to the required testing. In total, Deloney refused to submit to evaluations by

medical professionals during 12 different sessions, six with Dr. Carla Dreyer and six

with Dr. David Smith. Additionally, his family members refused to cooperate with

the experts in their evaluations Deloney’s refusal to comply became such an

obstruction that, at one point, Deloney was sent to Summit Behavioral Healthcare for

an extended period to determine his competence to stand trial. After doctors

determined that he was competent to stand trial, the trial court set a hearing on the

Atkins motion, deciding to use what evidence the parties had been able to muster

without his cooperation.

2 O HIO F IRST D ISTRICT C OURT OF A PPEALS The Hearing

{¶3} On August 17, 2015, the trial court conducted a hearing on Deloney’s

motion. Drs. Smith and Dreyer both submitted reports. In Smith’s report, he noted

that he had reviewed some school records, and reports prepared by other medical

professionals involved in the case. But, because of Deloney’s failure to cooperate

with the evaluation, Smith could not reach a conclusion about whether Deloney had

significant limitations in two or more adaptive skills. Smith wrote that

The clearest conclusion to be drawn is that under the current

circumstances I am unable to give a definitive appraisal about whether

Mr. John Deloney has Mental Retardation or Intellectual Disability at

this time. Thus, it is likely that the court will need to proceed

regarding his charges. Should Mr. Deloney be found guilty, then the

question might be better answered should he comply with

standardized testing, and if at least one other informant is found to

give reports of his adaptive functioning.

Dreyer, faced with the same obstacles, reached similar conclusions. She wrote that

As the Court is aware, multiple attempts have been made to formally

assess the defendant’s intellectual and adaptive functioning to

determine if he suffers from mental retardation (also known as an

intellectual disability). While he has not cooperated with various

assessments, including the undersigned’s current assessment attempt,

available records were reviewed in relationship to the referral

questions. A discussion of this information is being provided to the

Court to assist in determining if the defendant is mentally retarded.

However, given the defendant’s lack of cooperation with the evaluation

and the absence of current intelligence testing and collateral

3 O HIO F IRST D ISTRICT C OURT OF A PPEALS

information from the family related to his childhood functioning, I am

unable to state, to a reasonable degree of psychological certainty, if the

defendant suffers from mental retardation that would allow the United

States Constitution to bar him from receiving the death penalty.

{¶4} In addition to the reports, both doctors testified at the hearing.

Smith, testifying for Deloney, said that he had explained to Deloney that he was there

to evaluate him to see if he qualified under Atkins as mentally retarded. He said that

Deloney seemed to understand, but refused to cooperate with him. Smith also

testified that the team at Summit Behavioral Healthcare had reported that, within

that structured environment, Deloney did not exhibit any deficient functioning,

either in navigating the rules or being able to occupy his time in different areas. But

Smith said that standing out in such a structured environment would have been

“pretty hard to do.”

{¶5} Smith also reviewed Deloney’s records from Cincinnati State

Technical and Community College, noting that he had not done well and had needed

developmental classes. But in discussing Deloney’s experience at Cincinnati State,

Smith admitted that he looked at only a single sheet of paper, and that it appeared to

be “a snapshot of someone who apparently crashed and burned.” But Smith also

admitted that he did not know what the requirements of the program were when he

made his evaluation of Deloney’s performance.

{¶6} Smith also reviewed Deloney’s employment records from Frisch’s and

Long John Silver’s. Deloney had worked at the two restaurants for a period of a few

months each. But the records from his employment there were very sparse,

containing no information about his job duties or his work performance. Smith

noted that the Frisch’s records did not give a reason for his termination, and that the

4 O HIO F IRST D ISTRICT C OURT OF A PPEALS

Long John Silver’s records indicated only that he was let go because he was “not able

to keep up.” All he could say about Deloney’s work history was that

[w]ell, he was not able to keep up with the job expectations. They

looked like positions within the kitchen. They looked like manual

labor positions that many individuals with mild intellectual disability

can do quite well. And he was not keeping up was all it said. It didn’t

have an extensive rationale for it, or what was going on. But that

would show the possibility that, again, he’s not showing independent

functioning in a vocational setting.

But, on cross-examination, Smith further conceded that his failure to perform at

work could also have been because he was simply unwilling to do the work assigned.

{¶7} Smith spoke at length about the refusal of Deloney to cooperate with

the Atkins evaluations. Smith agreed with defense counsel that Deloney’s

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Related

State v. Martin
2025 Ohio 144 (Ohio Court of Appeals, 2025)
State v. Deloney
2019 Ohio 5213 (Ohio Court of Appeals, 2019)

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2017 Ohio 9282, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-deloney-ohioctapp-2017.