State v. Vanmeter

2024 Ohio 1458
CourtOhio Court of Appeals
DecidedApril 17, 2024
Docket30461, 30462, 30463, 30464
StatusPublished
Cited by1 cases

This text of 2024 Ohio 1458 (State v. Vanmeter) 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. Vanmeter, 2024 Ohio 1458 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Vanmeter, 2024-Ohio-1458.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

STATE OF OHIO C.A. Nos. 30461, 30462 30463, 30464 Appellee

v. APPEAL FROM JUDGMENT JACK VANMETER ENTERED IN THE COURT OF COMMON PLEAS Appellant COUNTY OF SUMMIT, OHIO CASE Nos. CR 19 07 2424 CR 20 03 0995 CR 20 07 1736 CR 20 12 3565

DECISION AND JOURNAL ENTRY

Dated: Appril 17, 2024

STEVENSON, Presiding Judge.

{¶1} Appellant, Jack Vanmeter, appeals from his convictions and sentences in four

separate cases in the Summit County Court of Common Pleas. For the reasons set forth below, this

Court affirms.

I.

{¶2} Mr. Vanmeter was charged with aggravated burglary in violation of R.C.

2911.11(A)(1) and R.C. 2911.11(B), a felony of the first degree; domestic violence in violation of

R.C. 2919.25(A) and R.C. 2919.25(D)(4), a felony of the third degree; violating a protection order

in violation of R.C. 2919.27(A)(1) and R.C. 2919.27(B)(4), a felony of the third degree; and

violating a protection order in violation of R.C. 2919.27(A)(1) and R.C. 2919.27(B)(3)(c), a felony

of the fifth degree. A supplemental indictment charged Mr. Vanmeter with felonious assault in 2

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

result of these charges, Mr. Vanmeter was also charged with CCV violations in three prior cases.

{¶3} Mr. Vanmeter pleaded not guilty to the charges in the indictment and supplemental

indictment and the trial court later granted his motion for competency and sanity evaluation. After

Dr. Wood of the court’s Psycho-Diagnostic Clinic issued an inconclusive report, the trial court

ordered that Mr. Vanmeter be transferred to Northcoast Behavioral Health (“Northcoast”) for

restoration.

{¶4} Dr. Marcus of Northcoast issued a report in April 2021, finding Mr. Vanmeter

competent. Mr. Vanmeter’s trial counsel and the State stipulated to Dr. Marcus’s report and the

competency finding. The trial court accepted the parties’ stipulation and entered a finding of

competency. Trial counsel did not further raise the issue of sanity or the request for a sanity

evaluation at this time.

{¶5} After final pretrial and trial dates were confirmed, new counsel was appointed after

Mr. Vanmeter’s former attorney was involved in an accident. After the appointment of new

counsel, Mr. Vanmeter moved for a reexamination of competency and sanity at an August 2021,

status conference. The trial court granted this motion and ordered competency and sanity

evaluations.

{¶6} The court’s Psycho-Diagnostic Clinic found Mr. Vanmeter competent upon

reexamination. Mr. Vanmeter did not further raise a sanity defense at this time.

{¶7} Mental health concerns were again raised at a November 2021, pretrial. According

to his counsel, Mr. Vanmeter was experiencing hallucinations because he was not receiving his

medications at the jail. The trial court granted counsel’s request to transport Mr. Vanmeter to 3

Northcoast and competency and sanity evaluations were again ordered. The State represented at

this hearing that Mr. Vanmeter previously declined to participate in a sanity evaluation.

{¶8} The trial court discovered at a December 2021, pretrial that Mr. Vanmeter was

never transported to Northcoast. Trial counsel again requested that Mr. Vanmeter be transported

to Northcoast for competency and sanity evaluations. The trial court granted this request.

{¶9} Dr. Stankowski of Northcoast issued a report in April 2022, finding Mr. Vanmeter

had been restored to competency. The State and trial counsel stipulated to this report and

competency finding at a May 2022, status conference. Dr. Testa informed the court at this status

conference that “Mr. Vanmeter’s stability is entirely dependent upon med compliance and the

structure of the hospital.” It was represented that Mr. Vanmeter was receiving the proper

medications and Mr. Vanmeter said that he felt “[g]reat.” The trial court accepted the parties’

stipulation and found that Mr. Vanmeter was competent to stand trial. The issue of Mr. Vanmeter’s

sanity was neither raised nor addressed at the May 2022, status conference.

{¶10} Mr. Vanmeter pleaded guilty in July 2022, to domestic violence, violating a

protection order, felonious assault, and the CCV violations in the prior cases. The trial court later

sentenced Mr. Vanmeter to 24 months on the domestic violence charge; 12 months on the violating

a protection order charge; and an indefinite sentence of four to six years on the felonious assault

charge, with the sentences to run concurrently. The State previously dismissed the other counts of

the indictment.

{¶11} The court imposed a reserved sentence of six months, to run concurrently, in each

of the three prior cases for the CCV violations. The court ordered that the sentences on the domestic

violence, violating a protection order, and felonious assault charges run consecutively with the

sentences imposed in the prior cases for the CCV violations. Credit was given for time served. 4

{¶12} Mr. Vanmeter appeals all four underlying criminal cases, asserting five assignments

of error for our review. Mr. Vanmeter withdrew his sixth assignment of error in his reply brief.

ASSIGNMENT OF ERROR I

THE TRIAL COURT VIOLATED APPELLANT’S RIGHT TO DUE PROCESS UNDER THE FIFTH AND FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION, AND ARTICLE I, SECTION 10 OF THE OHIO CONSTITUTION, IN FINDING APPELLANT COMPETENT TO STAND TRIAL WITHOUT CONDUCTING AN EVIDENTIARY HEARING[.]

{¶13} Mr. Vanmeter argues in his first assignment of error that the trial court violated his

right to due process under the Fifth and Fourteenth Amendments to the United States Constitution,

and Article I, Section 10 of the Ohio Constitution, when it found him competent to stand trial

without conducting an evidentiary hearing. We disagree.

{¶14} “A criminal defendant is presumed competent.” State v. Coker, 9th Dist. Summit

No. 29540, 2021-Ohio-2910, ¶ 8. “[T]he burden is on the defendant to prove by a preponderance

of the evidence that he is not competent.” State v. Were, 118 Ohio St.3d 448, 2008-Ohio-2762, ¶

45.

{¶15} In determining competency, the question is “‘whether [the defendant] has sufficient

present ability to consult with his lawyer with a reasonable degree of rational understanding—and

whether he has a rational as well as factual understanding of the proceedings against him.’” State

v. Berry, 72 Ohio St.3d 354, 359 (1995), quoting Dusky v. United States, 362 U.S. 402 (1960).

“One who lacks the capacity to understand the nature and object of the proceedings against him,

to consult with counsel, and to assist in preparing his defense may not stand trial.” State v. Smith,

9th Dist. Summit No. 27389, 2015-Ohio-2842, ¶ 9, citing State v. Skatzes, 104 Ohio St.3d 195,

2004-Ohio-6391, ¶ 155. 5

{¶16} The Ohio Supreme Court has clarified that “[i]ncompetency must not be equated

with mere mental or emotional instability or even with outright insanity” and that “[a] defendant

may be emotionally disturbed or even psychotic and still be capable of understanding the charges

against him and of assisting his counsel.” State v. Bock, 28 Ohio St.3d 108, 110 (1986). “The

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2024 Ohio 1458, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-vanmeter-ohioctapp-2024.