State v. Deloney

2023 Ohio 1013, 212 N.E.3d 343
CourtOhio Court of Appeals
DecidedMarch 29, 2023
DocketC-220433
StatusPublished
Cited by1 cases

This text of 2023 Ohio 1013 (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, 2023 Ohio 1013, 212 N.E.3d 343 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Deloney, 2023-Ohio-1013.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-220433 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: Affirmed

Date of Judgment Entry on Appeal: March 29, 2023

Melissa A. Powers, Hamilton County Prosecuting Attorney, and Ronald W. Springman, Assistant Prosecuting Attorney, for Plaintiff-Appellant,

Faulkner & Tepe, LLP, A. Norman Aubin and Richard G. Wendel II, for Defendant- Appellee. OHIO FIRST DISTRICT COURT OF APPEALS

BERGERON, Judge.

{¶1} Charged with aggravated murder with death penalty specifications,

defendant-appellee John Deloney has sat in the Hamilton County Justice Center,

waiting for trial, for a decade. Following a hearing in 2022, the trial court determined

that Mr. Deloney is intellectually disabled and thus constitutionally ineligible for the

death penalty. The state appealed, generally asserting that the trial court somehow

erred in making this determination. But the state fails to address, or even mention,

any of the findings made by the trial court in its 13-page decision. For the reasons

explained below, the state’s appeal is meritless, and we affirm the trial court’s

judgment.

I.

{¶2} After a man was shot to death inside his own pizza restaurant, Mr.

Deloney was indicted in June 2013 for one count of aggravated murder with death

penalty and firearm specifications and one count of aggravated robbery with a firearm

specification. The facts underlying Mr. Deloney’s charges are not relevant to our

analysis, as the state appeals only the trial court’s decision to preclude the death

penalty in his case after finding him intellectually disabled.

{¶3} In December 2013, following the indictment, Mr. Deloney filed a

“Motion for Suggestion of Mental Retardation,” citing to a psychological evaluation in

which he obtained a full-scale IQ score of 63. In August 2015, the trial court conducted

an Atkins hearing on the motion during which both sides presented expert testimony

and submitted exhibits. See Atkins v. Virginia, 536 U.S. 304, 122 S.Ct. 2242, 153

L.Ed.2d 335 (2002). A central theme of this hearing was Mr. Deloney’s refusal to

cooperate with the experts or his attorneys. In September 2015, the trial court issued

2 OHIO FIRST DISTRICT COURT OF APPEALS

a 22-page entry finding, “by a preponderance of the evidence, that Defendant suffers

from intellectual disability. Accordingly, * * * Defendant John Deloney is excluded

from facing a possible death sentence herein.”

{¶4} The state appealed that decision to this court, and in State v. Deloney,

1st Dist. Hamilton No. C-150619, 2017-Ohio-9282, this court reversed the trial court’s

decision and remanded the cause for further proceedings. We held that the trial court

erred in its determination of an intellectual disability under the governing case law of

Atkins, and State v. Lott, 97 Ohio St.3d 303, 2002-Ohio-6625, 779 N.E.2d 1011,

because Mr. Deloney failed to establish through expert testimony a sufficient causal

link between his intellectual disability and any significant adaptive limitations.

{¶5} A couple of years after our decision, in late 2019, the Ohio Supreme

Court issued its decision in State v. Ford, 158 Ohio St.3d 139, 2019-Ohio-4539, 140

N.E.3d 616, which restructured the framework for consideration of an intellectual

disability under Atkins in Ohio. Both sides agreed that Mr. Deloney’s potential

intellectual disability needed to be re-examined in light of the new legal standard, and

the trial court accordingly convened a second Atkins hearing in March 2022. The same

experts testified at this second hearing, and Mr. Deloney continued to refuse

psychological testing, cooperate with counsel, or cooperate with the experts. But the

experts had access to more details about Mr. Deloney’s employment history, a

deposition taken of his partner, and further information regarding his adulthood

academic and intellectual performance, including his records from Cincinnati State

Technical and Community College, indicating that he needed to take certain

developmental classes before qualifying for admission (which he never took). The

experts also had the opportunity to interact with Mr. Deloney over a greater time

3 OHIO FIRST DISTRICT COURT OF APPEALS

period and accounted for the changed legal standard in rendering their analyses at this

second hearing. In August 2022, the trial court found that Mr. Deloney satisfied the

new standard set forth in Ford, thus rendering him ineligible for the death penalty.

{¶6} In October 2022, this court granted the state leave to appeal. In its sole

assignment of error, the state asserts that the trial court erred as a matter of law in

finding Mr. Deloney to be intellectually disabled.

II.

{¶7} We must begin our analysis by noting that the state fails, anywhere in

its brief, to identify any error committed by the trial court. In Ford, the Ohio Supreme

Court required trial courts to make express findings reflective of their analyses. Ford

at ¶ 100 (“The trial court shall make written findings and set forth its rationale for

finding the defendant intellectually disabled or not intellectually disabled.”). The

reason for this directive is to facilitate appellate review in these very serious cases,

where a person’s life hangs in the balance.

{¶8} The trial court here followed that mandate, issuing 13 pages of detailed

findings assessing the evidentiary record. The state does not address any of those

findings in its appellate brief, nor does it address the relevant standard of review,

violating various provisions of App.R. 16 and 1st Dist. Loc.R. 16.1 See App.R. 16(A)(3);

1st Dist. Loc.R. 16.1(A)(4)(c)-(d).

1As best we can tell, the state merely cut and pasted the analysis it submitted to the trial court for a post-hearing (pre-decision) brief into the analysis section of its brief on appeal, which would explain the absence of references to the trial court’s decision, the failure to discuss the standard of review, and the like.

4 OHIO FIRST DISTRICT COURT OF APPEALS

{¶9} We accordingly begin where the state’s brief should have, with the

standard of review. It is well-established that “[t]he trial court’s decision on a

postconviction Atkins claim should be upheld absent an abuse of discretion.” State v.

Williams, 2021-Ohio-241, 167 N.E.3d 527, ¶ 33 (11th Dist.), citing State v. White, 118

Ohio St.3d 12, 2008-Ohio-1623, 885 N.E.2d 905, ¶ 45. Because pretrial and

postconviction Atkins claims are governed by the same authorities, we see no reason

to depart from the standard of review for postconviction Atkins claims when reviewing

a pretrial claim. And upon being questioned at oral argument, the state agreed with

this position. We therefore review a trial court’s decision on a pretrial Atkins claim for

an abuse of discretion. And we will not overturn a trial court’s findings that are

supported by some competent, credible evidence. See Williams at ¶ 33 (“A reviewing

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

Related

State v. Deloney
2025 Ohio 2458 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 1013, 212 N.E.3d 343, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-deloney-ohioctapp-2023.