State v. Heckler

2025 Ohio 1888
CourtOhio Court of Appeals
DecidedMay 27, 2025
Docket7-24-08
StatusPublished

This text of 2025 Ohio 1888 (State v. Heckler) 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. Heckler, 2025 Ohio 1888 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Heckler, 2025-Ohio-1888.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT HENRY COUNTY

STATE OF OHIO, CASE NO. 7-24-08 PLAINTIFF-APPELLEE,

V.

DEREK A. HECKLER, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

Appeal from Henry County Common Pleas Court Trial Court No. 24 CR 0024

Judgment Affirmed

Date of Decision: May 27, 2025

APPEARANCES:

Brian A. Smith for Appellant

Gwen Howe-Gebers for Appellee Case No. 7-24-08

WALDICK, P.J.

{¶1} Defendant-appellant, Derek A. Heckler (“Heckler”), brings this appeal

from the June 26, 2024, judgment of the Henry County Common Pleas Court

sentencing him to prison after he was convicted by a jury of Extortion, Trespass in

a Habitation Where a Person is Likely to be Present, three counts of Sexual Battery,

Violating a Protection Order, and Obstructing Official Business. On appeal, Heckler

argues that the trial judge demonstrated bias during plea negotiations and Heckler’s

trial counsel was ineffective for failing to file an “Affidavit of Disqualification” with

the Supreme Court of Ohio. In addition, Heckler argues that his convictions were

against the manifest weight of the evidence, and that the trial court did not make the

required findings pursuant to R.C. 2929.14(C)(4) to impose consecutive sentences

at the sentencing hearing. For the reasons that follow, we affirm the judgment of the

trial court.

Background

{¶2} On February 28, 2024, Heckler was indicted for Extortion in violation

of R.C. 2905.11(A)(5), a third degree felony (Count 1); Trespass in a Habitation

Where a Person is Likely to be Present in violation of R.C. 2911.12(B), a fourth

degree felony (Count 2); Violating a Protection Order in violation of R.C.

2919.27(A)(2), a first degree misdemeanor (Count 3); three counts of Sexual Battery

in violation of R.C. 2907.03(A)(1), all third degree felonies (Count 4-6); and -2- Case No. 7-24-08

Obstructing Official Business in violation of R.C. 2921.31(A), a fifth degree felony

(Count 7). Heckler pled not guilty to the charges.

{¶3} On May 9, 2024, Heckler proceeded to a jury trial wherein he was

convicted of Counts 1-6, and a lesser-included version of Count 7, Obstructing

Official Business as a second degree misdemeanor. On June 25, 2024, Heckler was

sentenced to serve an aggregate 6-year prison term.1 A judgment entry

memorializing his sentence was filed June 26, 2024. It is from this judgment that he

appeals, asserting the following assignments of error for our review.

First Assignment of Error

Because the trial judge demonstrated bias and prejudice toward Appellant in comments made during plea negotiations, and prior to Appellant’s trial, the failure of Appellant’s trial counsel to file an Affidavit of Disqualification with the Ohio Supreme Court, pursuant to R.C. 2701.03, constituted ineffective assistance of counsel, in violation of Appellant’s right to counsel under the Sixth and Fourteenth Amendments to the United States Constitution and Article I, Section 10 of the Ohio Constitution.

Second Assignment of Error

Because the jury lost its way and created a manifest miscarriage of justice in convicting Appellant, Appellant’s convictions were against the manifest weight of the evidence.

1 The breakdown of Heckler’s sentence is contained in the analysis of the third assignment of error.

-3- Case No. 7-24-08

Third Assignment of Error

Because the trial court did not make the required findings, pursuant to R.C. 2929.14(C)(4), to impose consecutive sentences, the trial court’s sentence of Appellant was contrary to law.

{¶4} In his first assignment of error, Heckler contends that he received

ineffective assistance of trial counsel because his trial counsel did not file an

“Affidavit of Disqualification” with the Supreme Court of Ohio seeking to remove

the trial judge for purported bias.

Standard of Review

{¶5} To prove ineffective assistance of counsel, the defendant must satisfy a

two-prong test; that counsel’s performance has fallen below an objective standard

of reasonable representation, and that he was prejudiced by counsel’s performance.

Strickland v. Washington, 466 U.S. 668, 687 (1984); State v. Bradley, 42 Ohio St.3d

136, at paragraph two of the syllabus (1989). To demonstrate prejudice, the

defendant must prove that, but for counsel’s errors, the result of the trial would have

been different. Id., paragraph three of the syllabus. Notably, in Ohio, a properly

licensed attorney is presumed to be competent and the burden is on the defendant to

prove otherwise. State v. Hamblin, 37 Ohio St.3d 153, 155 (1988). Moreover,

counsel is not deemed deficient for failing to file meritless motions. State v. Kelley,

2008-Ohio-6598, ¶ 76 (7th Dist.).

-4- Case No. 7-24-08

Analysis

{¶6} Revised Code 2701.03 governs the issue of judicial bias related to a

common pleas court judge. It reads, in pertinent part, as follows:

(A) If a judge of the court of common pleas allegedly is interested in a proceeding pending before the court, allegedly is related to or has a bias or prejudice for or against a party to a proceeding pending before the court or a party’s counsel, or allegedly otherwise is disqualified to preside in a proceeding pending before the court, any party to the proceeding or the party’s counsel may file an affidavit of disqualification with the clerk of the supreme court in accordance with division (B) of this section.

The preceding statutory subsection makes it clear that generally the determination

of a claim that a common pleas judge is biased is within the exclusive jurisdiction

of the Chief Justice of the Supreme Court of Ohio or her designee. State v. Bender,

2021-Ohio-1931, ¶ 18 (3d Dist.). It is important to emphasize that this is the only

avenue to disqualify a common pleas court judge and a defendant cannot forgo this

procedure and present it to the court of appeals “in order to avoid Supreme Court

jurisdiction.” State v. Corchado, 2017-Ohio-4390, ¶ 13 (7th Dist.).

{¶7} As this Court has previously stated when addressing allegations that a

trial judge should have been disqualified, “a court of appeals is without the authority

to determine whether a judge of the court of common pleas is, or should be,

disqualified from presiding over a case.” State v. Milligan, 2008–Ohio-4509, ¶ 11

-5- Case No. 7-24-08

(3d Dist.); State v. Holdcroft, 2010-Ohio-6262 (3d Dist.). Thus we lack the authority

to decide whether the trial judge should have been disqualified.

{¶8} Notably, there is an exception to the general rule stated above. We have

held that a “due process issue may still exist” because a criminal trial before a

“biased” judge is fundamentally unfair. Bender at ¶ 19. Accordingly, appellate

courts “ha[ve] the authority to review a claim of judicial bias as it impacts the

outcome of the case.” State v. Loudermilk, 2017-Ohio-7378, ¶ 18 (1st Dist.). In this

analysis, “[t]rial judges are presumed to be fair, impartial and unbiased.” In re A.H.,

2019-Ohio-4063, ¶ 65 (8th Dist.). For this reason, “the appearance of bias or

prejudice must be compelling to overcome these presumptions.” Matter of C.S.,

2003-Ohio-3754, ¶ 24 (4th Dist.); State v. Dixon, 2025-Ohio-326 (3d Dist.).

{¶9} Heckler attempts to subvert the jurisdictional barrier of judicial

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Bonnell (Slip Opinion)
2014 Ohio 3177 (Ohio Supreme Court, 2014)
State v. Hunter
2011 Ohio 6524 (Ohio Supreme Court, 2011)
State v. Holdcroft
2010 Ohio 6262 (Ohio Court of Appeals, 2010)
State v. Marcum (Slip Opinion)
2016 Ohio 1002 (Ohio Supreme Court, 2016)
State v. Kelley
903 N.E.2d 365 (Ohio Court of Appeals, 2008)
State v. Loudermilk
2017 Ohio 7378 (Ohio Court of Appeals, 2017)
In re A.H.
2019 Ohio 4063 (Ohio Court of Appeals, 2019)
State v. Bender
2021 Ohio 1931 (Ohio Court of Appeals, 2021)
State v. Hamblin
524 N.E.2d 476 (Ohio Supreme Court, 1988)
State v. Bradley
538 N.E.2d 373 (Ohio Supreme Court, 1989)
State v. Corchado
93 N.E.3d 150 (Court of Appeals of Ohio, Seventh District, Mahoning County, 2017)
State v. Bradshaw
2023 Ohio 1244 (Ohio Court of Appeals, 2023)
State v. Dixon
2025 Ohio 326 (Ohio Court of Appeals, 2025)
State v. Thompkins
1997 Ohio 52 (Ohio Supreme Court, 1997)

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2025 Ohio 1888, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-heckler-ohioctapp-2025.