State v. McDougald

2022 Ohio 3191
CourtOhio Court of Appeals
DecidedSeptember 8, 2022
Docket21-CA-3961
StatusPublished
Cited by3 cases

This text of 2022 Ohio 3191 (State v. McDougald) 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. McDougald, 2022 Ohio 3191 (Ohio Ct. App. 2022).

Opinion

[Cite as State v. McDougald, 2022-Ohio-3191.]

COURT OF APPEALS SCIOTO COUNTY, OHIO FOURTH APPELLATE DISTRICT

JUDGES: STATE OF OHIO : Hon. W. Scott Gwin, P.J. : Hon. William B. Hoffman, J. Plaintiff-Appellee : Hon. John W. Wise, J., : -vs- : Sitting by Assignment by the : Ohio Supreme Court JEROME MCDOUGALD AKA : JERONE MCDOUGALD : : Case No. 21-CA-3961 Defendant-Appellant : : : OPINION

CHARACTER OF PROCEEDING: Criminal appeal from the Scioto County Court of Common Pleas, Case No. 19- CR1055

JUDGMENT: Affirmed

DATE OF JUDGMENT ENTRY: September 8, 2022

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

SHANE A. TIEMAN SHAWN STRATTON Prosecuting Attorney 602 Chillicothe Street, Suite 441 BY: MATTHEW F. LOESCH Portsmouth, OH 45662 Assistant Prosecutor 612 6th Street, Room E Portsmouth, OH 45662 Scioto County, Case No. 21-CA-3961 2

Gwin, P.J.

{¶1} Defendant-appellant Jerome McDougald, aka Jerone McDougald

[“McDougald”] appeals his conviction after a jury trial in the Scioto County Court of

Common Pleas.

Facts and Procedural History

{¶2} On March 28, 2019, McDougald was an inmate at the Southern Ohio

Correctional Facility. Michael Englehardt was a correctional officer at the facility. On that

morning, Englehardt accompanied Nurse Laura Hart on her rounds to pass out the

morning medication to the inmates in McDougald’s cellblock.

{¶3} The pair approached McDougald’s cell and asked him if he wanted his

medications. As Englehardt began to open the hatch on the cell door to hand McDougald

his medications, McDougald responded, “F**k you.” He then spat “between the crack

between the two doors where the door opens.” T. at 174. Mr. Englehardt testified that

the spittle struck him on the shirt and pants. Id. at 176. The incident was captured on

the facilities security cameras. State’s Exhibit 1.

{¶4} Englehardt’s shirt and pants were collected as evidence, photographed,

and submitted to the Ohio Bureau of Criminal Investigation crime laboratory. Sara

Grimsley testified that Englehardt’s shirt tested positive for amylase a substance found in

several bodily fluids including saliva. She further testified that no DNA testing was done

in this case. T. at 214; 224.

{¶5} On October 22, 2019, McDougald was indicted in Scioto County Court of

Common Pleas case number 19-CR-1055 on two counts of Harassment by an Inmate

with a Bodily Substance in violation of R.C. 2921.38 (A)/(D). Scioto County, Case No. 21-CA-3961 3

{¶6} On March 1, 2021, the trial court granted the state’s motion to dismiss Count

1 of the indictment. [Docket Number 60].

{¶7} The jury found McDougald guilty of Count 2 of the indictment. The trial court

ordered McDougald to serve a twelve-month prison sentence to run consecutive to his

current prison term.

Assignments of Error

{¶8} McDougald raises two Assignments of Error,

{¶9} “I. THE TRIAL COURT'S FAILURE TO GRANT MR. MCDOUGALD'S

MOTION TO DISMISS VIOLATED HIS STATE AND FEDERAL CONSTITUTIONAL

RIGHTS TO A SPEEDY TRIAL.

{¶10} “II. THE DEFENSE COUNSEL APPOINTED TO REPRESENT THE

DEFENDANT IN THIS CASE DID NOT PROVIDE EFFECTIVE ASSISTANCE OF

COUNSEL.”

I.

{¶11} In his First Assignment of Error, McDougald argues that the trial court

violated his right to a speedy trial.

STANDARD OF APPELLATE REVIEW

{¶12} Speedy trial provisions are mandatory and are encompassed within the

Sixth Amendment to the United States Constitution. The availability of a speedy trial to a

person accused of a crime is a fundamental right made obligatory on the states through

the Fourteenth Amendment. State v. Ladd, 56 Ohio St.2d 197, 200, 383 N.E.2d 579

(1978). “The statutory speedy trial provisions, R.C. 2945.71 et seq., constitute a rational

effort to enforce the constitutional right to a public speedy trial of an accused charged with Scioto County, Case No. 21-CA-3961 4

the commission of a felony or a misdemeanor and shall be strictly enforced by the courts

of this state.” State v. Pachay, 64 Ohio St.2d 218, 416 N.E.2d 589 (1980), syllabus.

{¶13} To determine whether there has been a denial of a defendant’s

constitutional right to a speedy trial, the court considers four factors identified in Barker v.

Wingo, 407 U.S. 514, 523, 92 S.Ct. 2182, 33 L.Ed.2d 101 (1972): “(1) the length of delay,

(2) the reason for the delay, (3) the defendant’s assertion of his right to a speedy trial,

and (4) the prejudice to the defendant.” State v. Hull, 110 Ohio St.3d 183, 2006-Ohio-

4252, 852 N.E.2d 706, ¶22, citing Barker at 530, 92 S.Ct. 2182, 33 L.Ed.2d 101. No

single factor controls the analysis, but the length of the delay is important. “Until there is

some delay which is presumptively prejudicial, there is no necessity for inquiry into the

other factors that go into the balance.” Barker at 530, 92 S.Ct. 2182. Generally, a delay

that approaches one year is presumptively prejudicial. Doggett v. United States, 505 U.S.

647, 112 S.Ct. 2686, 120 L.Ed.2d 520 (1992), fn. 1. Accord, State v. Long, 163 Ohio

St.3d 179, 2020-Ohio-5363, 168 N.E.3d 1163, ¶14.

{¶14} Our review of a trial court’s decision regarding a motion to dismiss based

upon a violation of the speedy trial provisions involves a mixed question of law and fact.

State v. Larkin, 5th Dist. No. 2004–CA–103, 2005-Ohio-3122, ¶11. Long, 163 Ohio St.3d

179, 2020-Ohio-5363, 168 N.E.3d 1163, ¶15. As an appellate court, we must accept as

true any facts found by the trial court and supported by competent, credible evidence.

State v. Taylor, 5th Dist. Richland No. 16 CA 17, 2016-Ohio-5912, ¶43, citing Larkin;

Long, 163 Ohio St.3d 179, 2020-Ohio-5363, 168 N.E.3d 1163, ¶15.

{¶15} With regard to the legal issues, however, we apply a de novo standard of

review and thus freely review the trial court’s application of the law to the facts. Long, Scioto County, Case No. 21-CA-3961 5

163 Ohio St.3d 179, 2020-Ohio-5363, 168 N.E.3d 1163, ¶15. When reviewing the legal

issues presented in a speedy-trial claim, we must strictly construe the relevant statutes

against the state. Brecksville v. Cook, 75 Ohio St.3d 53, 57, 661 N.E.2d 706, 709 (1996);

State v. Colon, 5th Dist. Stark No. 09-CA-232, 2010-Ohio-2326, ¶12.

Issues for appellate review: Whether the trial court permissibly extended the

trial date beyond the R.C. 2945.71 time prescriptions; whether McDougald was brought

to trial within a reasonable period consistent with constitutional standards.

{¶16} A person charged with a felony shall be brought to trial within 270 days after

the person's arrest or the service of summons. R.C. 2945.71(C)(2). Because McDougald

was serving a prison sentence at the time of the offense, the triple count provisions of

R.C. 2945.71(E) do not apply. The Ohio Supreme Court has held that the triple count

provision only applies when the person is being held in jail in lieu of bail solely on the

pending case. State v. McDonald, 48 Ohio St.2d 66, 357 N.E.2d 40(1976), paragraph

one of the syllabus. In addition, the first day is excluded from the count. State v. Adkins,

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Bluebook (online)
2022 Ohio 3191, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mcdougald-ohioctapp-2022.