State v. Lofton

2023 Ohio 2796
CourtOhio Court of Appeals
DecidedAugust 11, 2023
DocketL-22-1111
StatusPublished
Cited by2 cases

This text of 2023 Ohio 2796 (State v. Lofton) 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. Lofton, 2023 Ohio 2796 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Lofton, 2023-Ohio-2796.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State of Ohio Court of Appeals No. L-22-1111

Appellee Trial Court No. CR0202101525

v.

Nevaeh Lofton DECISION AND JUDGMENT

Appellant Decided: August 11, 2023

*****

Julia R. Bates, Lucas County Prosecuting Attorney, and Lauren Carpenter, Assistant Prosecuting Attorney, for appellee.

Michael H. Stahl, for appellant.

OSOWIK, J.

{¶ 1} This is an appeal from the judgment by the Lucas County Court of Common

Pleas, which sentenced appellant, Neveah Lofton, to an indefinite prison term of four to

six years for felonious assault after the trial court accepted appellant’s Alford guilty plea

and convicted her of that offense. For the reasons set forth below, this court affirms, in

part, and reverses, in part, the judgment of the trial court. I. Background

{¶ 2} The following undisputed facts are relevant to this appeal. On April 13,

2021, the Lucas County Grand Jury indicted appellant on one count of felonious assault,

in violation of R.C. 2903.11(A)(1) and (D), a felony in the second degree. R.C.

2903.11(A)(1) states, “No person shall knowingly * * * (1) cause serious physical harm

to another[.]” The Lucas County Grand Jury also indicted appellant on one count of

felonious assault, in violation of R.C. 2903.11(A)(2) and (D), a felony in the second

degree. R.C. 2903.11(A)(2) states, “No person shall knowingly * * * (2) cause or attempt

to cause physical harm to another * * * by means of a deadly weapon[.]” Appellee, state

of Ohio, gave the factual basis for the charges: that on or about January 10, 2021, in

Toledo, Lucas County, Ohio, appellant drove her car, a red Ford Fusion, into the victim

and pinned the victim against a building, instantly breaking one leg. The victim was

hospitalized with serious injuries and has undergone numerous surgeries.

{¶ 3} Appellant entered not-guilty pleas, and the matter proceeded to trial. On the

morning of trial, on February 15, 2022, appellant changed her plea to guilty, pursuant to

North Carolina v. Alford, 400 U.S. 25, 91 S.Ct. 160, 27 L.Ed.2d 162 (1970), to one count

of felonious assault, in violation of R.C. 2903.11(A)(1) and (D), a felony in the second

degree. In the plea agreement, appellee dismissed the second count of felonious assault

with a deadly weapon, recommended a four-to-six-year sentence, and recommended a

no-contact order with the victim. After an extensive plea colloquy, the trial court

2. accepted appellant’s plea and found her guilty of the offense. Later, the trial court

sentenced appellant to serve an indefinite prison term of four to six years. At sentencing,

the trial court summarized the evidence against appellant and her criminal history.

Court: Ms. Lofton, it was clear from the video footage that the police

obtained from the nearby business that you intentionally ran down the

victim. As she was running down the alley[;] you struck her, pinning her to

the building. It goes without saying that you caused her serious physical

harm, as well as psychological harm. There was a severe laceration that she

suffered to her leg, and bone was protruding from that wound, which

resulted in several surgeries. Despite the video footage, you claim you had

nothing to do with this. You are 20 years old and you have three felony

convictions as a juvenile, and you’re wanted in Monroe, Michigan on

outstanding warrants for domestic violence and two assault offenses.

{¶ 4} Appellant timely appealed the trial court judgment setting forth one

assignment of error: “Neveah Lofton was denied effective assistance of counsel under the

Ohio and United States Constitutions when her lawyer, who was later permitted to resign

from the practice of law with disciplinary proceedings pending, was completely

unprepared for trial and entered an Alford guilty plea with the jury already empaneled.”

3. II. Ineffective Assistance of Counsel

{¶ 5} In support of her sole assignment of error, appellant argues that her trial

counsel, Frank Simmons, was ineffective for two reasons: failing to request a competency

evaluation when she has no memory of the offence and demonstrating his ignorance by

equating her lack of competency with recalcitrance on the issue of guilt, not her failure to

remember. Appellant argues the trial court erred by accepting her Alford guilty plea to

felonious assault, and by finding her guilty, when her mental health issues “were before

the court”: that she had an unmedicated bipolar disorder at the time of the plea.

Appellant further argues her trial counsel was ineffective because since filing the notice

of appeal on May 11, he resigned from the practice of law in Ohio with discipline

pending. Appellant concludes that her trial counsel’s failure to investigate her

competency prior to offering her Alford guilty plea should be reversed on plain error,

after employing a more nuanced analysis than usually followed in Strickland v.

Washington, 466 U.S. 668, 80 L.Ed.2d 674, 104 S.Ct. 2052 (1984).

{¶ 6} Appellee responds that appellant does not meet her burden to show her trial

counsel was ineffective at the time of her Alford guilty plea for a number of reasons.

First, the thorough plea colloquy by the trial court established appellant was a currently-

pregnant, 20-year-old mother of two infants who did not complete the 12th grade, but

understood the proceedings and was satisfied with the amount of time she had with her

trial counsel and with his advice. Second, at sentencing, appellant’s trial counsel raised

4. the issues of her bipolar and ADHD diagnoses since her youth because he reviewed her

presentence investigation report with her. Third, appellant’s incompetency claim is

traceable to her failure to take the necessary medications to maintain her mental health at

the time of the offense because of her succession of pregnancies. Nevertheless, appellant

confirmed that she has continuously received mental health counseling for her issues.

Fourth, her trial counsel recommended the plea deal because, although she maintained

her innocence, “she was closely knitted to this case,” and the presentence investigation

report included “significant statements” by her: the actual car involved was hers; the car

was at one point under her control; the car is “part of the reason why the victim was

injured”; and “instead of being convicted by a jury and, possibly, sentenced to the high

end,” i.e., the maximum minimum of eight years to maximum of 12 years if the

convictions were merged at sentencing, the plea agreement recommended four-to-six

years, and appellant retained opportunities for probation and access to mental health care.

Fifth, her trial counsel offered mitigation at sentencing that the trial court could “probably

help her, help the community, help her children, help her family” with a sentence that

provides her access to the mental health care she needs, such as receiving the medications

during incarceration, access to probation, or diversion to a correctional treatment facility.

Finally, appellant’s trial counsel was fully licensed during the entire time he represented

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 2796, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lofton-ohioctapp-2023.