State v. Hall

Ohio Court of Appeals·Decided August 19, 2026·No. 115264·Published

Opinion

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, :

No. 115264

v. :

MARK HALL, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: APPLICATION DENIED RELEASED AND JOURNALIZED: August 19, 2026

Cuyahoga County Court of Common Pleas Case No. CR-24-695031-A

Application for Reopening Motion No. 596056

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Kristen L. Hatcher, Assistant Prosecuting Attorney, for appellee.

Mark Hall, pro se.

TIMOTHY W. CLARY, J.:

Mark Hall (“Hall”), pro se, has filed an application for reopening pursuant to App.R. 26(B) and State v. Murnahan, 63 Ohio St.3d 60 (1991), based on claims of ineffective assistance of appellate counsel. Hall is attempting to reopen this court’s judgment in State v. Hall, 2026-Ohio-1042 (8th Dist.), in which this court affirmed Hall’s convictions and sentence. For the reasons that follow, we deny Hall’s application to reopen the appeal.

In September 2024, Hall was named in a ten-count indictment in Cuyahoga C.P. No. CR-24-695031-A, charging him two counts of rape (Counts 1 and 2), two counts of attempted rape (Count 3 and 4), two counts of kidnapping (Counts 5 and 6), a single count of felonious assault (Count 7), two counts of strangulation (Counts 8 and 9), and a single count of operating a motor vehicle under the influence of drugs or alcohol (“OVI”) (Count 10). Several of the charges included repeat- violent-offender (“RVO”) specifications, sexually violent predator (“SVP”) specifications, and notice-of-prior-conviction (“NPC”) specifications, and one count of strangulation included a furthermore clause. The indictment stemmed from allegations that Hall physically and sexually assaulted the alleged victim, M.A., in August 2024.

Following a jury trial, Hall was convicted of two counts of kidnapping (Counts 5 and 6), two counts of strangulation (Counts 8 and 9), and single counts of rape (Count 1), attempted vaginal rape (Count 3), felonious assault (Count 7), and OVI (Count 10). The jury subsequently found that Hall was a sexually violent predator, as alleged in the indictment.

In May 2025, Hall was sentenced to an aggregate prison term of “life imprisonment with parole eligibility after serving a full 39 years of imprisonment.” Hall was also classified as a Tier III sex offender.

In June 2025, Hall filed a direct appeal from his convictions and sentence. Therein, Hall raised seven assignments of error, arguing (1) the State failed to present sufficient evidence to support a conviction for each offense, (2) his convictions are against the manifest weight of the evidence, (3) he was denied his right to effective assistance of counsel, (4) the trial court erred by admitting highly prejudicial and inadmissible evidence during the SVP hearing, (5) the trial court erred by refusing to provide jury instructions on lesser-included and inferior offenses, (6) the trial court erred by failing to merge allied offenses of similar import for the purposes of sentencing, and (7) the trial court’s imposition of consecutive sentences was contrary to law. Upon review, this court found no merit to Hall’s claims and affirmed the trial court’s judgment. State v. Hall, 2026-Ohio-1042 (8th Dist.).

On April 29, 2026, Hall filed a timely application to reopen his appeal.

However, this court struck the original application because it exceeded the ten-page limitation established by App.R. 26(B). With leave of court, Hall filed a complying, amended application to reopen on June 5, 2026. The amended application does not set forth definitive, proposed assignments of error as contemplated under App.R. 26(B)(2)(c). Instead, Hall generally argues that appellate counsel rendered ineffective assistance of counsel by failing to challenge (1) trial counsel’s failure to challenge the credibility of Hall’s accuser, (2) the denial of Hall’s rights to a 90-day speedy trial, full discovery, a suppression hearing, and “facial grooming prior to trial,” and (3) trial counsel’s erroneous legal advice regarding a possible plea, which caused Hall to doubt future advice from counsel. Hall further suggests that appellate counsel was ineffective for failing to speak with him in preparation for his appeal.

On July 27, 2026, the State filed a brief in opposition to the amended application for reopening, arguing that Hall “has failed to show that there is a genuine issue that he was deprived of the effective assistance of counsel on appeal.” II. Law and Analysis A. Standard of Review Under App.R. 26(B), a defendant in a criminal case may apply to reopen his or her direct appeal of the judgment of conviction and sentence based on a claim of ineffective assistance of appellate counsel. The application must be filed within ninety days from journalization of the appellate judgment unless the applicant shows good cause for filing at a later time. App.R. 26(B)(1).

App.R. 26(B) establishes a two-stage procedure for adjudicating claims of ineffective assistance of appellate counsel. State v. Leyh, 2022-Ohio-292, ¶ 19. An applicant must first make a threshold showing that appellate counsel was ineffective. Id. at ¶ 19, 35. At this stage, an applicant is “not required to conclusively establish ineffective assistance of appellate counsel[.]” Id. at ¶ 35. Rather, “[t]he burden is on the applicant to demonstrate a ‘genuine issue’ as to whether there is a ‘colorable claim’ of ineffective assistance of appellate counsel.” Id. at ¶ 21, quoting State v. Spivey, 84 Ohio St.3d 24, 25 (1998).

If the applicant makes the required threshold showing, demonstrating that “there is at least a genuine issue — that is, legitimate grounds —

to support the claim that the applicant was deprived of the effective assistance of counsel on appeal,” then the application shall be granted and the appeal reopened. Id. at ¶ 25, citing App.R. 26(B)(5). The matter then “proceeds to the second stage of the procedure, which ‘involves filing appellate briefs and supporting materials with the assistance of new counsel, in order to establish that prejudicial errors were made in the trial court and that ineffective assistance of appellate counsel in the prior appellate proceedings prevented these errors from being presented effectively to the court of appeals.’” Id. at ¶ 22, quoting 1993 Staff Notes to App.R. 26(B).

Claims of ineffective assistance of appellate counsel under App.R.

26(B) are subject to the two-pronged analysis enunciated in Strickland v. Washington, 466 U.S. 668 (1984). See State v. Simpson, 2020-Ohio-6719, ¶ 14, id. at ¶ 23 (O’Connor, C.J., concurring). In accordance with the Strickland analysis, an applicant must show that (1) appellate counsel’s performance was objectively unreasonable, and (2) there is “a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Smith v. Robbins, 528 U.S. 259, 285-286 (2000). “A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Strickland at 694.

In considering Hall’s application, we are mindful that appellate counsel is afforded deference in determining which issues to argue on appeal. State v. Burke, 2002-Ohio-5310, ¶ 7. As this court has previously explained:

With respect to claims of ineffective assistance of appellate counsel, the United States Supreme Court has upheld the appellate advocate’s prerogative to decide strategy and tactics by selecting the most promising arguments and focusing on one central issue or, at most, a few key issues. State v. Barrow, 2015-Ohio-4579, ¶ 7 (8th Dist.), citing Jones v. Barnes, 463 U.S. 745, 751-52 (1983). See also State v. Ware, 2014-Ohio-815, ¶ 5 (8th Dist.) (“Appellate counsel cannot be considered ineffective for failing to raise every conceivable assignment of error on appeal.”).

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Related

Jones v. Barnes
463 U.S. 745 (Supreme Court, 1983)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Smith v. Robbins
528 U.S. 259 (Supreme Court, 2000)
State v. Ware
2014 Ohio 815 (Ohio Court of Appeals, 2014)
State v. Thomas
2015 Ohio 4486 (Ohio Court of Appeals, 2015)
State v. Simpson (Slip Opinion)
2020 Ohio 6719 (Ohio Supreme Court, 2020)
State v. Leyh (Slip Opinion)
2022 Ohio 292 (Ohio Supreme Court, 2022)
State v. Ishmail
377 N.E.2d 500 (Ohio Supreme Court, 1978)
State v. Murnahan
584 N.E.2d 1204 (Ohio Supreme Court, 1992)
State v. Spivey
701 N.E.2d 696 (Ohio Supreme Court, 1998)
State v. Townsend
2022 Ohio 4398 (Ohio Court of Appeals, 2022)
State v. Burke
2002 Ohio 5310 (Ohio Supreme Court, 2002)
State v. Hall
2026 Ohio 1042 (Ohio Court of Appeals, 2026)