State v. Pritchard

Ohio Court of Appeals·Decided July 16, 2026·No. CT2025-0122, CT2025-0140·Published

Opinion

[Cite as State v. Pritchard, 2026-Ohio-2733.]

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT MUSKINGUM COUNTY, OHIO

STATE OF OHIO, Case No. CT2025-0122 CT2025-0140 Plaintiff - Appellee Opinion And Judgment Entry -vs- Appeal from the Muskingum County Court of THOMAS PRITCHARD, Common Pleas, Case Nos. CR2023-0347, CR2023-0213 Defendant - Appellant Judgment: Affirmed

Date of Judgment Entry: July 16, 2026

BEFORE: William B. Hoffman; Craig R. Baldwin; David M. Gormley, Judges

APPEARANCES: JOSEPH PALMER, Assistant Prosecuting Attorney, for Plaintiff- Appellee; BRIAN W. BENBOW, for Defendant-Appellant.

Baldwin, J.

{¶1} The appellant, Thomas Pritchard, appeals his convictions and sentences

following his guilty pleas in the Muskingum County Court of Common Pleas. The appellee

is the State of Ohio.

STATEMENT OF FACTS AND THE CASE

{¶2} On March 29, 2023, the Muskingum County Grand Jury indicted the appellant

on four counts of Kidnapping in violation of R.C. 2905.01(A)(2) and R.C. 2905.01(B)(1), one

count of Grand Theft of a Motor Vehicle in violation of R.C. 2913.02(A)(1) and one count of

Escape in violation of R.C. 2921.34(A)(1) in Case No. CR2023-0213. {¶3} On May 31, 2023, the Muskingum County Grand Jury returned a second

indictment charging the appellant with one count of Receiving Stolen Property in violation

of R.C. 2913.51(A) and one count of OVI in violation of R.C. 4511.19(A)(1)(a) in Case No.

CR2023-0347.

{¶4} On November 18, 2024, the appellant, through counsel, notified the trial court

of his intent to raise the issue of his competence to stand trial.

{¶5} The appellant was evaluated by Dr. Dreyer in January of 2025. Dr. Dreyer

reported that the appellant was not capable of rationally understanding the legal proceedings

and was not capable of adequately assisting counsel in his defense. The trial court

subsequently found the appellant incompetent to stand trial and ordered treatment for

restoration to competency at Appalachian Behavioral Healthcare.

{¶6} In August of 2025, once appellant had received mental-health treatment for

several months, psychologist Amanda Conn evaluated whether he had been restored to

competency and prepared a report documenting her findings. Dr. Conn concluded that the

appellant was capable of understanding the nature and objectives of the proceedings against

him and was capable of assisting counsel in his defense.

{¶7} On September 2, 2025, the trial court conducted a competency-restoration

proceeding. The parties stipulated to the August 2025 restoration report. Neither party

presented additional evidence or requested the testimony of the evaluator. Defense counsel

did not request a second competency evaluation. Based upon the stipulated report, the trial

court found that the appellant had been restored to competency.

{¶8} On September 22, 2025, the appellant appeared with counsel and entered

negotiated pleas of guilty. In Case No. CR2023-0213, the appellant pleaded guilty to two counts of kidnapping and one count of grand theft of a motor vehicle. In Case No. CR2023-

0347, the appellant pleaded guilty to receiving stolen property and OVI.

{¶9} During the plea colloquy, the trial court reviewed the nature of the charges, the

potential penalties, the constitutional rights the appellant would waive, postrelease control,

and the consequences of the pleas. The appellant responded to the trial court’s questions,

asked questions concerning the financial sanctions and other consequences of his pleas, stated

he understood the proceedings, and expressed satisfaction with counsel. The trial court

accepted the appellant’s pleas and found him guilty.

{¶10} The trial court conducted a sentencing hearing on October 27, 2025. The

appellant addressed the trial court and offered his version of the underlying events. The trial

court imposed an aggregate indefinite prison term of twenty-one to twenty-six years in Case

No. CR2023-0213. The trial court imposed an aggregate twelve-month prison term in Case

No. CR2023-0347, to be served consecutively to the sentence imposed in Case No. CR2023-

0213.

{¶11} The appellant filed a timely appeal and raised the following two assignments of

error:

{¶12} “I. TRIAL COUNSEL RENDERED INEFFECTIVE ASSISTANCE OF

COUNSEL BY FAILING TO CHALLENGE THE RESTORATION-TO-

COMPETENCY EVALUATION, FAILING TO REQUEST A SECOND

EVALUATION, AND ALLOWING THE PROCEEDINGS TO CONTINUE WITHOUT

A MEANINGFUL DETERMINATION OF THE APPELLANT’S COMPETENCY.”

{¶13} “II. THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY

ACCEPTING THE DEFENDANT’S PLEA WITHOUT CONDUCTING THE COMPETENCY HEARING REQUIRED BY R.C. 2945.37(B), AFTER THE

DEFENDANT’S COMPETENCY WAS RAISED BEFORE TRIAL.”

I.

{¶14} In his first assignment of error, the appellant argues that he was denied effective

assistance of counsel in violation of his rights under both the United States Constitution and

the Ohio Constitution. We disagree.

STANDARD OF REVIEW

{¶15} The standard of review for ineffective assistance of counsel was set forth in the

seminal case of Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984),

and was discussed by this Court in Mansfield v. Studer, 2012-Ohio-4840 (5th Dist.):

A claim of ineffective assistance of counsel requires a two-prong

analysis. The first inquiry is whether counsel’s performance fell below an

objective standard of reasonable representation involving a substantial

violation of any of defense counsel’s essential duties to appellant. The second

prong is whether the appellant was prejudiced by counsel’s ineffectiveness.

Lockhart v. Fretwell (1993), 506 U.S. 364, 113 S.Ct. 838, 122 L.Ed.2d 180 (1993);

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

(1984); State v. Bradley (1989), 42 Ohio St.3d 136, 538 N.E.2d 373 (1989).

In order to warrant a finding that trial counsel was ineffective, the

petitioner must meet both the deficient performance and prejudice prongs of

Strickland and Bradley. Knowles v. Mirzayance, 556 U.S. 111, 129 S.Ct. 1411,

1419, 173 L.Ed.2d 251 (2009). To show deficient performance, appellant must establish that “counsel’s

representation fell below an objective standard of reasonableness.” Strickland v.

Washington, 466 U.S. at 688, 104 S.Ct. at 2064. This requires showing that

counsel made errors so serious that counsel was not functioning as the “counsel”

guaranteed the defendant by the Sixth Amendment. Strickland v. Washington, 466

U.S. at 687, 104 S.Ct. at 2064. Counsel also has a duty to bring to bear such skill

and knowledge as will render the trial a reliable adversarial process. Strickland v.

Washington, 466 U.S. at 688, 104 S.Ct. 2052 (sic) at 2065.

Thus, a court deciding an actual ineffectiveness claim must judge the

reasonableness of counsel’s challenged conduct on the facts of the particular

case, viewed as of the time of counsel’s conduct. A convicted defendant

making a claim of ineffective assistance must identify the acts or omissions

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