State v. Hayes

2025 Ohio 121
CourtOhio Court of Appeals
DecidedJanuary 16, 2025
DocketCT2024-0085
StatusPublished
Cited by3 cases

This text of 2025 Ohio 121 (State v. Hayes) 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. Hayes, 2025 Ohio 121 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Hayes, 2025-Ohio-121.]

COURT OF APPEALS MUSKINGUM COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO : JUDGES: : Hon. William B. Hoffman, P.J. Plaintiff-Appellee : Hon. Craig R. Baldwin, J. : Hon. Andrew J. King, J. -vs- : : BERNARD L. HAYES : Case No. CT2024-0085 : Defendant-Appellant : OPINION

CHARACTER OF PROCEEDING: Appeal from the Court of Common Pleas, Case No. CR2021-0664

JUDGMENT: Affirmed

DATE OF JUDGMENT: January 16, 2025

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

JOSEPH A. PALMER BERNARD L. HAYES, PRO SE 27 North Fifth Street Belmont Correctional Facility Zanesville, OH 43702 #797-924 P.O. Box 504 St. Clairsville, OH 43950 Muskingum County, Case No. CT2024-0085 2

King, J.

{¶ 1} Defendant-Appellant Bernard L. Hayes appeals the July 10, 2024 judgment

of the Muskingum County Court of Common Pleas denying his petition for post-conviction

relief. Plaintiff-Appellee is the State of Ohio. We affirm the trial court.

Facts and Procedural History

{¶ 2} A full recitation of the underlying facts is unnecessary for our resolution of

this appeal. Relevant here, on December 4, 2021, following an overdose of insulin, Hayes

was transported by ambulance to Genesis Hospital, where he was treated by Dr. Philip

Kray and his blood sugar levels stabilized. Dr. Kray testified at trial that he was concerned

that Hayes's insulin overdose was indicative of possible self-harm so he issued a writ

placing Hayes "on hold," or as Hayes' refers to it a "pink slip," thus preventing the Hayes

from leaving the hospital. Dr. Kray testified that he communicated to Hayes the precise

reasons he was required to stay in the emergency department for treatment, during which

Hayes was conscious and alert. State v. Hayes, 2023-Ohio-1008 ¶ 4 (5th Dist.) (Hayes

I).

{¶ 3} Hayes became angry and aggressive, and indicated that he wanted to

leave. Dr. Kray again attempted to explain to Hayes the reasons why he had been placed

on a hold. Hayes became more upset, and attempted to get up from the bed while

attached to a number of monitors and an IV. The victim, Genesis Hospital Security Officer

Garret Wohlford was called to the treatment room to assist with the disturbance. Dr. Kray

testified that Hayes got out of bed and moved towards himself and Officer Wohlford. An

altercation ensued, during which Officer Wohlford suffered significant cranial injuries.

Hayes I ¶ 5. Muskingum County, Case No. CT2024-0085 3

{¶ 4} Following jury trial in the Muskingum County Common Pleas Court, Hayes

was convicted of felonious assault on a peace officer and was sentenced to a term of

incarceration of eleven to sixteen and one-half years. He appealed to this Court, and we

affirmed the judgment of conviction and sentence. State v. Hayes, 2023-Ohio-1008 (5th

Dist.). Relevant to this appeal, Hayes raised ineffective assistance of counsel in his direct

appeal for failing to challenge whether the victim was a peace officer.

{¶ 5} Hayes also filed a timely petition for postconviction relief in the trial court,

arguing the State improperly withheld evidence in discovery, and counsel was ineffective

for failing to properly investigate the case prior to trial. The trial court summarily dismissed

the petition without findings of fact and conclusions of law.

{¶ 6} Hayes filed a notice of appeal to this Court. The State moved to dismiss on

the basis a judgment dismissing a petition for postconviction relief without findings of fact

and conclusions of law is not a final appealable order. This Court granted the motion and

dismissed the appeal. Hayes appealed to the Ohio Supreme Court. The Supreme Court

accepted the appeal and summarily reversed this Court's dismissal on the authority of

State ex rel. Penland v. Dinkelacker, 2020-Ohio-3774 and remanded the case to this

Court for a decision on the merits. This Court reopened the appeal. We found the trial

court erred in failing to issue findings of fact and conclusions of law and remanded the

matter for the same. State v. Hayes, 2024-Ohio-1825 (5th Dist.) (Hayes II).

{¶ 7} On July 10, 2024, the trial court issued its findings of fact and conclusions

of law and denied Hayes' petition without a hearing.

{¶ 8} Hayes timely filed an appeal and the matter is now before this court for

consideration. He raises ten assignments of error as follow: Muskingum County, Case No. CT2024-0085 4

I

{¶ 9} "THE TRIAL COURT ABUSED ITS DISCRETION AND ERRED IN

ISSUING INADEQUATE AND ERRONEOUS FINDING OF FACT AND CONCLUSION

OF LAW IN DISMISSAL OF HAYES PETITION FOR POSTCONVICTION RELIEF."

II

{¶ 10} "THE TRIAL JUDGE ERRED IN FAILING TO GRANT THE APPELLANT

AN EVIDENTIARY HEARING AS IS REQUIRED BY R.C. 2953.21(C)."

III

{¶ 11} "THE TRIAL COURT ABUSED ITS DISCRETION AND ERRED AS A

MATTER OF LAW WHEN IT DENIED APPELLANT’S MOTION FOR AN ORDER

COMPELLING THE PROSECUTOR TO PRODUCE THE PINK SLIP WRIT."

IV

{¶ 12} "THE TRIAL COURT ABUSED ITS DISCRETION AND ERRED AS A

MATTER OF LAW WHEN IT DENIED APPELLANT’S MOTION FOR DISCOVERY OF

THE "PINK SLIP" WHERE THE FINDINGS MADE BY THE TRIAL COURT TO

SUPPORT THE DECISION IS NOT WITHIN THE RECORD, AND THE PROSECUTOR

ADMITTED THAT HE NEVER HAD ACCESS TO THE PINK SLIP."

V

{¶ 13} "THE APPELLANT WAS DENIED HIS RIGHT TO DUE PROCESS AND

RIGHT TO A FAIR TRIAL GUARANTEED BY THE FOURTEENTH AMENDMENT OF

THE UNITED STATES AND OHIO CONSTITUTIONS WHEN THE STATE COMMITTED

A BRADY VIOLATION BY FAILING TO DISCLOSE EXCULPATORY EVIDENCE OF

THE ("PINK SLIP DOCUMENT")." Muskingum County, Case No. CT2024-0085 5

VI

{¶ 14} "THE APPELLANT WAS DENIED HIS RIGHT TO DUE PROCESS AND

RIGHT TO A FAIR TRIAL GUARANTEED BY THE FOURTEENTH AMENDMENT OF

THE UNITED STATES AND OHIO CONSTITUTIONS WHEN THE STATE COMMITTED

A BRADY VIOLATION BY FAILING TO DISCLOSE EXCULPATORY EVIDENCE OF

OFFICER WOHLFORD’S OPATA PEACE OFFICER TRAINING AND TESTING

CERTIFICATION."

VII

{¶ 15} "THE APPELLANT WAS DENIED HIS RIGHT TO DUE PROCESS AND

RIGHT TO A FAIR TRIAL GUUARANTEED BY THE FOURTEENTH AMENDMENT OF

THE UNITED STATES AND OHIO CONSTITUTIONS WHEN THE STATE COMMITED

A BRADY VIOLATION BY FAILING TO DISCLOSE EXCULPATORY EVIDENCE OF

OFFICER WOHLFORD’S EMPLOYMENT RECORDS."

VIII

{¶ 16} "THE APPELLANT WAS DENIED HIS RIGHT TO A FAIR TRIAL

GUARANTEED BY THE FOURTEENTH AMENDMENT OF THE UNITED STATES AND

OHIO CONSTITUTIONS WHEN THE STATE COMMITED A BRADY VIOLATION BY

FAILING TO DISCLOSE EXCULPATORY EVIDENCE OF WHETHER OFFICER

WOHLFORD WAS LICENSED AND/OR AUTHORIZED TO CARRY A FIREARM. "

IX

{¶ 17} "APPELLANT WAS DENIED THE EFFECTIVE ASSISTANCE OF TRIAL

COUNSEL WHEN COUNSEL FAILED TO CONDUCT PROPER PRE-TRIAL

INVESTIGATION AND DISCOVERY, WITH THE STATE, ON WHETHER OFFICER Muskingum County, Case No. CT2024-0085 6

WOHLFORD HAD A CERTIFICATE OF SATISFACTORY COMPLETION OF AN

APPROVED STATE, COUNTY, OR MUNICIPAL PEACE OFFICER TRAINING

PROGRAM."

X

{¶ 18} "APPELLANT WAS DENIED THE EFFECTIVE ASSISTANCE OF TRIAL

INVESTIGATION AND DISCOVERY, WHERE COUNSEL FAILED TO OBTAIN THE

"PINK SLIP WRIT DOCUMENT" FILLED OUT BY DR. KRAY THAT ALLEGEDLY

PLACED A 72-HOUR PSYCHIATRIC HOLD."

I, II

{¶ 19} Because they are interrelated, we address Hayes' first and second

assignments of error together.

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2025 Ohio 121, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hayes-ohioctapp-2025.