State v. Mikhak

CourtOhio Court of Appeals
DecidedJune 5, 2026
Docket2025-CA-36
StatusPublished

This text of State v. Mikhak (State v. Mikhak) 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. Mikhak, (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Mikhak, 2026-Ohio-2106.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT GREENE COUNTY

STATE OF OHIO : : C.A. No. 2025-CA-36 Appellee : : Trial Court Case No. 2018 CR 0611 v. : : (Criminal Appeal from Common Pleas CHRISTOPHER A. MIKHAK : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on June 5, 2026, the judgment of the

trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MARY K. HUFFMAN, JUDGE

TUCKER, J., and EPLEY, J., concur. OPINION GREENE C.A. No. 2025-CA-36

RICHARD HEMPFLING, Attorney for Appellant MEGAN A. HAMMOND, Attorney for Appellee

HUFFMAN, J.

{¶ 1} Christopher Mikhak appeals from the decision of the Greene County Common

Pleas Court finding him to be a mentally ill person subject to hospitalization, terminating his

conditional release, and remanding him to the Ohio Department of Mental Health, Summit

Behavioral Healthcare Campus (“SBH”). In the absence of an abuse of discretion, the

judgment of the trial court is affirmed.

Procedural History

{¶ 2} On August 17, 2018, Mikhak was indicted on two counts of aggravated burglary,

two counts of felonious assault, two counts of abduction, and one count each of aggravated

robbery, causing serious harm to a companion animal, and carrying a concealed weapon.

All counts contained firearm specifications, and all but the carrying a concealed weapon

count contained forfeiture specifications. Mikhak pleaded not guilty by reason of insanity on

November 5, 2028.

{¶ 3} On December 6, 2018, defense counsel for filed a motion to determine Mikhak’s

competency to stand trial. On April 1, 2019, the State requested an evaluation of Mikhak’s

sanity at the time of the offense. The court granted the motions and ordered the evaluations.

On June 12, 2019, after an evaluation, a report, and a hearing, the court found Mikhak

competent to stand trial.

{¶ 4} After a jury trial, on November 8, 2019, Mikhak was found not guilty by reason

of insanity on both counts of aggravated burglary, abduction, and aggravated robbery, as

2 well as causing serious harm to a companion animal, and not guilty of felonious assault and

carrying a concealed weapon. On November 22, 2019, the State filed a motion for an

evaluation under R.C. 2945.40, and the court granted the motion.

{¶ 5} On December 11, 2019, the court issued a judgment entry finding Mikhak to be

a mentally ill person subject to hospitalization and presently in need of inpatient treatment,

which was later amended on December 17, 2019. In its judgment entry, the court committed

him to SBH, “the least restrictive commitment alternative consistent with public safety and

the welfare of the Defendant.”

{¶ 6} Over the next two and a half years, the court granted greater privileges to

Mikhak; he received Level III privileges on April 8, 2020, Level IV privileges on March 11,

2021, and Level V privileges on December 22, 2021. Finally, on November 9, 2022, the

court granted Mikhak conditional release to a group home managed by TCN Behavioral

Health Services (TCN) as recommended by SBH. The court allowed Mikhak to leave the

State for a trip to Washington, D.C., by entry on August 28, 2023. He was also given

permission to travel to Florida on November 17, 2023, and December 12, 2024.

{¶ 7} On October 1, 2024, Mikhak filed a motion for independent living outside of the

group home, attaching an opinion by his psychologist at TCN stating that he was ready to

move into his own residence. The court denied the motion, finding that the “treatment

provider for the defendant is not in agreement at this time.” On December 9, 2025, the court

ordered an evaluation regarding conditional release. Dr. Carla Dreyer of the Forensic

Psychiatry Center for Western Ohio evaluated Mikhak and submitted a report on January 8,

2025. She concluded that Mikhak “is a mentally ill person subject to court order, although

he is not an intellectually disabled individual subject to institutionalization.” Dreyer found that

the least restrictive setting was conditional release with his current group home placement.

3 {¶ 8} After defense counsel requested that Mikhak be reexamined, the court granted

the motion on February 19, 2025. A forensic psychological evaluation was conducted by

Dr. D. Richard Bromberg, Ph.D., on March 17, 2025. He recommended a series of

successive steps in the group home setting with the ultimate goal of independent living.

{¶ 9} On April 4, 2025, Mikhak was taken into custody pursuant to R.C. 2945.402(C)

for alleged violations of his conditional release plan. On the same day, the court ordered a

mandatory evaluation pursuant to R.C. 2945.401 to take place on April 10, 2025, at the

Forensic Psychiatry Center for Western Ohio.

{¶ 10} On April 14, 2025, Mikhak filed a motion for his release from jail to TCN on

electronic home detention pending a decision by the court regarding the least restrictive

setting. The court issued an entry sua sponte indicating that it was awaiting a report from

the Forensic Psychiatry Center for Western Ohio, and it continued the ten-day period within

which it was required to conduct a hearing to determine if Mikhak’s conditional release

should be modified or terminated. Dreyer conducted the examination, and in her April 30,

2025 report, she opined that “the least restrictive setting for Mr. Mikhak while under court

jurisdiction is a state psychiatric hospital.”

{¶ 11} At a May 1, 2025 hearing, both parties orally moved to continue the

proceedings, and the court granted the motions. The court further issued an entry denying

Mikhak’s motion to be released from jail. On June 26, 2025, Bromberg submitted another

report concluding that Mikhak’s “current psychological and behavioral stability suggest that

he remains capable of cooperating with his Conditional Release and capable of returning to

the group home and continuing to move toward increased independence.”

{¶ 12} The conditional release hearing occurred on June 27, 2025, at which Dreyer

and Bromberg testified. Dreyer’s April 30, 2025 report, and Bromberg’s June 26, 2025 report

4 were admitted. The court’s subsequent entry stated that Bromberg’s April 5, 2025 report was

provided by defense counsel. The court found Mikhak to be a mentally ill person subject to

hospitalization under R.C. 2945.40(F) and presently in need of hospitalization. The court

ordered that Mikhak be returned to jail for transport to SBH as soon as a bed became

available. Mikhak timely appealed.

Conditional Release Hearing

{¶ 13} Before addressing Mikhak’s assigned errors, we review the transcript of the

conditional release hearing on June 27, 2025. At the start thereof, the State and Defense

counsel stipulated to the qualifications of Dreyer and Bromberg.

{¶ 14} Dreyer stated that she evaluated Mikhak on December 19, 2024, in response

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Cite This Page — Counsel Stack

Bluebook (online)
State v. Mikhak, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mikhak-ohioctapp-2026.