State v. Deloney

2019 Ohio 5213
CourtOhio Court of Appeals
DecidedDecember 18, 2019
DocketC-190372
StatusPublished

This text of 2019 Ohio 5213 (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, 2019 Ohio 5213 (Ohio Ct. App. 2019).

Opinion

[Cite as State v. Deloney, 2019-Ohio-5213.] IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-190372 TRIAL NO. B-1303726 Plaintiff-Appellee, :

vs. : O P I N I O N.

JOHN DELONEY, :

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed and Cause Remanded

Date of Judgment Entry on Appeal: December 18, 2019

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

Faulkner & Tepe, LLP, A. Norman Aubin and Wilkes R. Ellsworth, for Defendant- Appellant. OHIO FIRST DISTRICT COURT OF APPEALS

MOCK, Presiding Judge.

{¶1} Defendant-appellant John Deloney has filed an interlocutory appeal

from the decision of the Hamilton County Court of Common Pleas denying his

motion to preclude the death penalty as a sentencing option on double-jeopardy

grounds. We find no merit in Deloney’s sole assignment of error, and we affirm the

trial court’s judgment.

I. Factual Background

{¶2} On June 21, 2013, Deloney was indicted for aggravated murder under

R.C. 2903.01(B), with accompanying death-penalty and firearm specifications. He

was also indicated for aggravated robbery under R.C. 2911.01(A)(1), with an

accompanying firearm specification.

{¶3} Deloney’s counsel subsequently filed a “Motion for a Suggestion of

Mental Retardation.” We note that the Ohio Supreme Court now uses the term

“intellectually disabled” rather than “mentally retarded.” See State v. Ford, Slip

Opinion No. 2019-Ohio-4539, ¶ 44. Therefore, we will also use the term

“intellectually disabled.”

{¶4} Despite the filing of the motion, Deloney and his family refused to

cooperate with all evaluations and testing. Eventually, the trial court held a hearing

using the evidence the parties had been able to gather without Deloney’s

cooperation. After the hearing, the trial court found that Deloney was intellectually

disabled. Therefore, it held that subjecting him to the death penalty would constitute

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

2242, 153 L.Ed.2d 335 (2002), and State v. Lott, 97 Ohio St.3d 303, 2002-Ohio-

6625, 779 N.E.2d 1011.

2 OHIO FIRST DISTRICT COURT OF APPEALS

{¶5} The state appealed the trial court’s decision to this court. In State v.

Deloney, 1st Dist. Hamilton No. C-150619, 2017-Ohio-9282, we reversed the trial

court’s decision, holding that Deloney had failed to meet his burden of proof to show

that he was intellectually disabled. We remanded the cause to the trial court for

further proceedings. Id. at ¶ 30. The Supreme Court declined to accept the case for

review. See State v. Deloney, 152 Ohio St.3d 1481, 2018-Ohio-1990, 98 N.E.3d 295.

{¶6} On remand, Deloney filed a “Motion to Preclude the Death Penalty,”

on double-jeopardy grounds. He argued that the trial court’s decision finding that he

was intellectually disabled was essentially an acquittal on the issue of whether the

state could impose the death penalty. The trial court denied the motion. It found

that the Atkins determination was unrelated to factual guilt and innocence, and

therefore, it was not an acquittal for purposes of the double-jeopardy clause. The

court also found that under the law-of-the-case doctrine, it was required to follow

our mandate and proceed to trial.

{¶7} Deloney filed a timely appeal from the trial court’s judgment. We note

that the Ohio Supreme Court has held that the denial of a motion to dismiss on

double-jeopardy grounds is a final, appealable order. See State v. Anderson, 138

Ohio St.3d 264, 2014-Ohio-542, 6 N.E.3d 23, ¶ 60-61.

{¶8} In his sole assignment of error, Deloney contends that the trial court

erred in overruling his motion to dismiss the death-penalty specifications on double-

jeopardy grounds. He argues that the law-of-the-case doctrine did not preclude the

trial court from considering the double-jeopardy issue. He also argues that the trial

court made a factual finding that he was intellectually disabled, which precluded the

imposition of the death penalty and served as an “acquittal” on the death-penalty

specifications. Therefore, regardless of our reversal of the trial court’s previous

3 OHIO FIRST DISTRICT COURT OF APPEALS

decision, trying him on the specifications would twice place him in jeopardy, and as a

result, the state is precluded from seeking the death penalty. This assignment of

error is not well taken.

II. Law-of-the-Case Doctrine

{¶9} First, the law-of-the-case doctrine did not bar the trial court from

deciding the double-jeopardy issue. Under the law-of-the-case doctrine, the decision

of a reviewing court in an action remains the law of that case on the legal questions

involved for all subsequent proceedings in that case. Nolan v. Nolan, 11 Ohio St.3d 1,

3, 462 N.E.2d 410 (1984); Vonderhaar v. Cincinnati, 191 Ohio App.3d 229, 2010-

Ohio-6289, 945 N.E.2d 603, ¶ 13 (1st Dist.). The law-of-the-case doctrine does not

apply when the subsequent proceedings involve different evidence or different legal

issues. Vonderhaar at ¶ 13.

{¶10} In our previous decision, we decided only that Deloney had failed to

meet his burden to show that he was intellectually disabled, and therefore, ineligible

for the death penalty. Whether the state is precluded by the Double Jeopardy Clause

from seeking the death penalty is a separate issue that we did not decide, and thus, it

is outside of our mandate. Therefore, the trial court was not barred by the law-of-

the-case doctrine from considering the double-jeopardy issue.

III. Double Jeopardy

{¶11} “The constitutional protection against double jeopardy unequivocally

prohibits a second trial following an acquittal.” State v. Hancock, 108 Ohio St.3d 57,

2006-Ohio-160, 840 N.E.2d 1032, ¶ 139, quoting Arizona v. Washington, 434 U.S.

497, 503, 98 S.Ct. 824, 54 L.Ed.2d 717 (1978). The Double Jeopardy Clause

4 OHIO FIRST DISTRICT COURT OF APPEALS

ordinarily does not prohibit the imposition of an increased sentence on remand from

an appeal. Hancock at ¶ 139. But in a line of cases beginning with Bullington v.

Missouri, 451 U.S. 430, 101 S.Ct. 1852, 68 L.Ed.2d 270 (1981), the United States

Supreme Court held that double-jeopardy principles may apply to bar a capital

sentence on retrial. Hancock at ¶ 140.

A. The United States Supreme Court Cases

{¶12} In Bullington, the jury originally returned a verdict rejecting the death

penalty and imposing a sentence of life imprisonment without parole eligibility for

50 years. Subsequently, the trial court granted the defendant’s motion for a new trial

on grounds related to statutory deficiencies in jury selection. The court refused to let

the state seek the death penalty on retrial, and the state sought a writ of prohibition

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Martin Linen Supply Co.
430 U.S. 564 (Supreme Court, 1977)
Arizona v. Washington
434 U.S. 497 (Supreme Court, 1978)
United States v. Scott
437 U.S. 82 (Supreme Court, 1978)
Bullington v. Missouri
451 U.S. 430 (Supreme Court, 1981)
Arizona v. Rumsey
467 U.S. 203 (Supreme Court, 1984)
Poland v. Arizona
476 U.S. 147 (Supreme Court, 1986)
Atkins v. Virginia
536 U.S. 304 (Supreme Court, 2002)
Sattazahn v. Pennsylvania
537 U.S. 101 (Supreme Court, 2003)
Commonwealth v. Sattazahn
763 A.2d 359 (Supreme Court of Pennsylvania, 2000)
State v. Anderson
2014 Ohio 542 (Ohio Supreme Court, 2014)
State v. White
2012 Ohio 2583 (Ohio Supreme Court, 2012)
State v. Arnold
2013 Ohio 5336 (Ohio Court of Appeals, 2013)
State v. Deloney
2017 Ohio 9282 (Ohio Court of Appeals, 2017)
State v. Soto (Slip Opinion)
2019 Ohio 4430 (Ohio Supreme Court, 2019)
State v. Ford (Slip Opinion)
2019 Ohio 4539 (Ohio Supreme Court, 2019)
Vonderhaar v. City of Cincinnati
945 N.E.2d 603 (Ohio Court of Appeals, 2010)
Nolan v. Nolan
462 N.E.2d 410 (Ohio Supreme Court, 1984)
State v. Stumpf
512 N.E.2d 598 (Ohio Supreme Court, 1987)
State v. Lott
97 Ohio St. 3d 303 (Ohio Supreme Court, 2002)
State v. Hancock
840 N.E.2d 1032 (Ohio Supreme Court, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
2019 Ohio 5213, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-deloney-ohioctapp-2019.