[Cite as State v. Wells, 2026-Ohio-2677.]
IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT ALLEN COUNTY
STATE OF OHIO, CASE NO. 1-25-55 PLAINTIFF-APPELLEE,
v.
KATELYN E. WELLS, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.
Appeal from Allen County Common Pleas Court Trial Court No. CR2024 0251
Judgment Affirmed
Date of Decision: June 13, 2026
APPEARANCES:
William T. Cramer for Appellant
John R. Willamowski, Jr. for Appellee Case No. 1-25-55
MILLER, J.
{¶1} Defendant-appellant, Katelyn E. Wells (“Wells”), appeals the September 16,
2025 judgment of conviction and sentence against her in the Allen County Court of
Common Pleas. For the reasons that follow, we affirm.
Facts and Procedural History
{¶2} On November 14, 2024, an Allen County grand jury indicted Wells for rape of
a child less than thirteen years of age in violation of R.C. 2907.02(A)(1)(b) and attempted
rape of a child less than thirteen years of age in violation of R.C. 2923.02 and R.C.
2907.02(A)(1)(b), both first-degree felonies. The rape count included an allegation that
the victim was under ten years of age at the time of the offense, which exposed Wells to a
sentence of life imprisonment without the possibility of parole under R.C. 2907.02(B). The
attempted-rape count carried a specification under R.C. 2941.1419(A) that the victim was
under ten, mandating a prison term of ten years to life.
{¶3} Wells pleaded not guilty by reason of insanity on November 22, 2024, and
further moved for competency and sanity evaluations. The court granted the motions and
ordered the evaluations to proceed. Dr. Carla S. Dreyer (“Dr. Dreyer”) conducted the
evaluation and observed that Wells presented with a “childlike” appearance attributable to
Shwachman-Diamond Syndrome. As an infant, Wells had undergone chemotherapy, blood
transfusions, and a bone marrow transplant. In her interview with Dr. Dreyer, Wells stated
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she experienced severe deficits in cognitive development, which her medical conditions
had adversely affected, and she was placed in special education programs throughout her
schooling. Dr. Dreyer estimated that Wells’s intellectual functioning fell within the “low
average” range. Dr. Dreyer further observed that Wells had previously received mental
health treatment for impulse control following a juvenile sex offense she committed at age
fourteen. According to Dr. Dreyer, Wells denied any symptoms indicative of a severe
mental illness and instead reported a history of impulse-control difficulties accompanied
by deviant sexual interest consistent with a paraphilic disorder. Dr. Dreyer reported that,
once educated about the proceedings and afforded additional time, Wells could describe
and comprehend the charges against her and the attendant legal proceedings. Dr. Dreyer
ultimately concluded that Wells was neither intellectually disabled nor mentally ill and that
she was capable of understanding the nature and objective of the proceedings and of
assisting in her own defense.
{¶4} At a competency hearing in January 2025, the parties stipulated to the
admission of Dr. Dreyer’s evaluation and Dr. Dreyer’s expert credentials and no additional
evidence was offered. Relying on the report, the court found Wells competent to stand
trial. In September 2025, Wells withdrew her earlier pleas and pleaded guilty to the rape
count in exchange for the State’s dismissal of the attempted-rape count and a stipulation to
a reduced sentence of fifteen years to life in prison. The trial court accepted the plea and
imposed the mandatory term of fifteen years to life consistent with the agreement. The
-3- Case No. 1-25-55
court further designated Wells a Tier III sex offender. Wells timely appealed. She raises a
single assignment of error.
Assignment of Error
Appellant’s Due Process rights were violated by an erroneous finding that she was competent to stand trial.
{¶5} In her sole assignment of error, Wells argues her due process rights were
violated when the trial court erroneously found her competent to stand trial and accepted
her plea of guilty.
Standard of Review
{¶6} Generally, a trial court’s competency finding is reviewed under an abuse of
discretion standard. State v. Jones, 2024-Ohio-1124, ¶ 19 (11th Dist.). A trial court does
not abuse its discretion in finding a defendant competent where its findings are supported
by some reliable, credible evidence. State v. Vrabel, 2003-Ohio-3193, ¶ 33 (“We find that
the trial court did not abuse its discretion in finding appellant competent. Under these
circumstances, we will not disturb the trial court’s findings, since there was some reliable,
credible evidence supporting them.”). However, when a party fails to object to the trial
court’s finding of competency, such finding is reviewed for plain error. In re E.C., 2015-
Ohio-4807, ¶ 5 (3d Dist.). “Generally, an appellate court need not review questions which
have not been raised in the trial court and upon which the trial court has had no opportunity
to rule. However, an appellate court may consider any errors that affect a substantial right
-4- Case No. 1-25-55
regardless of whether they were brought to the attention of the trial court.” (Citations
omitted.) Id. “For this Court to notice plain error, the error must be an obvious defect in a
trial’s proceedings, it must have affected substantial rights, and it must have affected the
outcome of the trial.” State v. Risner, 2019-Ohio-4120, ¶ 41 (3d Dist.). “Moreover, ‘even
when the minimum requirements have been met, a reviewing court should still be
conservative in its application of plain-error review, reserving notice of plain error for
situations involving more than merely theoretical prejudice to substantial rights.’” Id.,
quoting State v. Steele, 2013-Ohio-2470, ¶ 30.
Analysis
{¶7} R.C. 2945.37(G) states:
A defendant is presumed to be competent to stand trial. If, after a hearing, the court finds by a preponderance of the evidence that, because of the defendant’s present mental condition, the defendant is incapable of understanding the nature and objective of the proceedings against the defendant or of assisting in the defendant’s defense, the court shall find the defendant incompetent to stand trial and shall enter an order authorized by section 2945.38 of the Revised Code.
Furthermore, “mental illness is not necessarily legal incompetency.” State v. Elliott, 2015-
Ohio-3766, ¶ 23 (8th Dist.).
{¶8} In the present case, a hearing was held during which both parties agreed to Dr.
Dreyer’s qualifications and stipulated to the admission of Dr. Dreyer’s report. Dr. Dreyer’s
report concluded Wells was competent to stand trial, specifically stating the following:
It is the undersigned’s professional opinion that Ms. Wells is not an intellectually disabled or mentally ill individual. It is also my opinion that
-5- Case No. 1-25-55
she is currently capable of understanding the nature and the objective of the proceedings against her and assisting in her defense. It therefore is my opinion that Ms. Wells is COMPETENT to stand trial.
{¶9} “Where the parties stipulate to the contents of the competency reports which
opine that the defendant is competent, the parties stipulate to competency[.]” State v.
O’Neill, 2004-Ohio-6805, ¶ 21 (7th Dist.). Further, the trial court may rely on the stipulated
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[Cite as State v. Wells, 2026-Ohio-2677.]
IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT ALLEN COUNTY
STATE OF OHIO, CASE NO. 1-25-55 PLAINTIFF-APPELLEE,
v.
KATELYN E. WELLS, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.
Appeal from Allen County Common Pleas Court Trial Court No. CR2024 0251
Judgment Affirmed
Date of Decision: June 13, 2026
APPEARANCES:
William T. Cramer for Appellant
John R. Willamowski, Jr. for Appellee Case No. 1-25-55
MILLER, J.
{¶1} Defendant-appellant, Katelyn E. Wells (“Wells”), appeals the September 16,
2025 judgment of conviction and sentence against her in the Allen County Court of
Common Pleas. For the reasons that follow, we affirm.
Facts and Procedural History
{¶2} On November 14, 2024, an Allen County grand jury indicted Wells for rape of
a child less than thirteen years of age in violation of R.C. 2907.02(A)(1)(b) and attempted
rape of a child less than thirteen years of age in violation of R.C. 2923.02 and R.C.
2907.02(A)(1)(b), both first-degree felonies. The rape count included an allegation that
the victim was under ten years of age at the time of the offense, which exposed Wells to a
sentence of life imprisonment without the possibility of parole under R.C. 2907.02(B). The
attempted-rape count carried a specification under R.C. 2941.1419(A) that the victim was
under ten, mandating a prison term of ten years to life.
{¶3} Wells pleaded not guilty by reason of insanity on November 22, 2024, and
further moved for competency and sanity evaluations. The court granted the motions and
ordered the evaluations to proceed. Dr. Carla S. Dreyer (“Dr. Dreyer”) conducted the
evaluation and observed that Wells presented with a “childlike” appearance attributable to
Shwachman-Diamond Syndrome. As an infant, Wells had undergone chemotherapy, blood
transfusions, and a bone marrow transplant. In her interview with Dr. Dreyer, Wells stated
-2- Case No. 1-25-55
she experienced severe deficits in cognitive development, which her medical conditions
had adversely affected, and she was placed in special education programs throughout her
schooling. Dr. Dreyer estimated that Wells’s intellectual functioning fell within the “low
average” range. Dr. Dreyer further observed that Wells had previously received mental
health treatment for impulse control following a juvenile sex offense she committed at age
fourteen. According to Dr. Dreyer, Wells denied any symptoms indicative of a severe
mental illness and instead reported a history of impulse-control difficulties accompanied
by deviant sexual interest consistent with a paraphilic disorder. Dr. Dreyer reported that,
once educated about the proceedings and afforded additional time, Wells could describe
and comprehend the charges against her and the attendant legal proceedings. Dr. Dreyer
ultimately concluded that Wells was neither intellectually disabled nor mentally ill and that
she was capable of understanding the nature and objective of the proceedings and of
assisting in her own defense.
{¶4} At a competency hearing in January 2025, the parties stipulated to the
admission of Dr. Dreyer’s evaluation and Dr. Dreyer’s expert credentials and no additional
evidence was offered. Relying on the report, the court found Wells competent to stand
trial. In September 2025, Wells withdrew her earlier pleas and pleaded guilty to the rape
count in exchange for the State’s dismissal of the attempted-rape count and a stipulation to
a reduced sentence of fifteen years to life in prison. The trial court accepted the plea and
imposed the mandatory term of fifteen years to life consistent with the agreement. The
-3- Case No. 1-25-55
court further designated Wells a Tier III sex offender. Wells timely appealed. She raises a
single assignment of error.
Assignment of Error
Appellant’s Due Process rights were violated by an erroneous finding that she was competent to stand trial.
{¶5} In her sole assignment of error, Wells argues her due process rights were
violated when the trial court erroneously found her competent to stand trial and accepted
her plea of guilty.
Standard of Review
{¶6} Generally, a trial court’s competency finding is reviewed under an abuse of
discretion standard. State v. Jones, 2024-Ohio-1124, ¶ 19 (11th Dist.). A trial court does
not abuse its discretion in finding a defendant competent where its findings are supported
by some reliable, credible evidence. State v. Vrabel, 2003-Ohio-3193, ¶ 33 (“We find that
the trial court did not abuse its discretion in finding appellant competent. Under these
circumstances, we will not disturb the trial court’s findings, since there was some reliable,
credible evidence supporting them.”). However, when a party fails to object to the trial
court’s finding of competency, such finding is reviewed for plain error. In re E.C., 2015-
Ohio-4807, ¶ 5 (3d Dist.). “Generally, an appellate court need not review questions which
have not been raised in the trial court and upon which the trial court has had no opportunity
to rule. However, an appellate court may consider any errors that affect a substantial right
-4- Case No. 1-25-55
regardless of whether they were brought to the attention of the trial court.” (Citations
omitted.) Id. “For this Court to notice plain error, the error must be an obvious defect in a
trial’s proceedings, it must have affected substantial rights, and it must have affected the
outcome of the trial.” State v. Risner, 2019-Ohio-4120, ¶ 41 (3d Dist.). “Moreover, ‘even
when the minimum requirements have been met, a reviewing court should still be
conservative in its application of plain-error review, reserving notice of plain error for
situations involving more than merely theoretical prejudice to substantial rights.’” Id.,
quoting State v. Steele, 2013-Ohio-2470, ¶ 30.
Analysis
{¶7} R.C. 2945.37(G) states:
A defendant is presumed to be competent to stand trial. If, after a hearing, the court finds by a preponderance of the evidence that, because of the defendant’s present mental condition, the defendant is incapable of understanding the nature and objective of the proceedings against the defendant or of assisting in the defendant’s defense, the court shall find the defendant incompetent to stand trial and shall enter an order authorized by section 2945.38 of the Revised Code.
Furthermore, “mental illness is not necessarily legal incompetency.” State v. Elliott, 2015-
Ohio-3766, ¶ 23 (8th Dist.).
{¶8} In the present case, a hearing was held during which both parties agreed to Dr.
Dreyer’s qualifications and stipulated to the admission of Dr. Dreyer’s report. Dr. Dreyer’s
report concluded Wells was competent to stand trial, specifically stating the following:
It is the undersigned’s professional opinion that Ms. Wells is not an intellectually disabled or mentally ill individual. It is also my opinion that
-5- Case No. 1-25-55
she is currently capable of understanding the nature and the objective of the proceedings against her and assisting in her defense. It therefore is my opinion that Ms. Wells is COMPETENT to stand trial.
{¶9} “Where the parties stipulate to the contents of the competency reports which
opine that the defendant is competent, the parties stipulate to competency[.]” State v.
O’Neill, 2004-Ohio-6805, ¶ 21 (7th Dist.). Further, the trial court may rely on the stipulated
report’s opinion, and the parties may waive any further hearing. Id. The trial court was,
therefore entitled to credit Dr. Dreyer’s stipulated opinion.
{¶10} Because Wells identifies no error in the competency determination, she
necessarily cannot satisfy plain error review. Plain error requires showing that, “but for
the error, the outcome of the trial clearly would have been otherwise.” State v. Long, 53
Ohio St.2d 91, 97 (1978). With an unrebutted, stipulated expert opinion in the record
supporting the trial court’s finding of competency, there is no evidence of error or legal
deviation, nothing obvious undermines the trial court’s determination, and there is no basis
to suggest the outcome would have differed.
{¶11} Wells’s argument on appeal does not identify any error in the competency
determination. She contends that her “extensive and disturbing medical and mental health
history” rendered her incompetent. (Appellant’s Brief at 5). But that history is precisely
what Dr. Dreyer reviewed and accounted for in opining that Wells was competent.
“Incompetency must not be equated with mere mental or emotional instability or even with
outright insanity. 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.
-6- Case No. 1-25-55
Bock, 28 Ohio St.3d 108, 110 (1986). The competency test focuses entirely on the
defendant’s ability to understand the proceedings and assist in the defense, which can be
satisfied regardless of the defendant’s mental status. See R.C. 2945.37(G) (the trial court
will find the defendant incompetent when it is proven by a preponderance of the evidence
that “the defendant is incapable of understanding the nature and objective of the
proceedings against the defendant or of assisting in the defendant’s defense”).
{¶12} In her evaluation of Wells, Dr. Dreyer observed Wells was capable of
communicating appropriately about courtroom procedure, the nature of her felony charges,
the meaning of the pleas she could enter, and the roles of defense counsel, the prosecuting
attorney, the judge, and probation. After minimal instruction, Dr. Dreyer also found Wells
was capable of understanding the role of a jury and the concept of a plea bargain. As to
her capacity to assist in her defense, Dr. Dreyer observed Wells was capable of relaying all
necessary information to her attorney in an adequate and appropriate manner, she had the
ability to understand and comprehend instructions and evaluate legal advice, she was able
to understand the role of a witness, and she possessed the capacity to testify.
{¶13} On appeal, Wells simply restates this report in a light more favorable to her
preferred finding of incompetency. However, the report, itself, concluded Wells is
competent to stand trial, both parties stipulated to the finding of the report and Dr. Dreyer’s
expert credentials, and the trial court was, therefore, within its discretion to rely on the
report’s findings. Accordingly, there is nothing in the record from which to find error.
{¶14} The assignment of error is overruled.
-7- Case No. 1-25-55
Conclusion
{¶15} For the foregoing reasons, Wells’s assignment of error is overruled. Having
found no error prejudicial to the defendant-appellant in the particulars assigned and argued,
the judgment of the Allen County Court of Common Pleas is affirmed.
ZIMMERMAN, P.J. and WALDICK, J., concur.
-8- Case No. 1-25-55
JUDGMENT ENTRY
For the reasons stated in the opinion of this Court, the assignment of error is
overruled and it is the judgment and order of this Court that the judgment of the trial court
is affirmed with costs assessed to Appellant for which judgment is hereby rendered. The
cause is hereby remanded to the trial court for execution of the judgment for costs.
It is further ordered that the Clerk of this Court certify a copy of this Court’s
judgment entry and opinion to the trial court as the mandate prescribed by App.R. 27; and
serve a copy of this Court’s judgment entry and opinion on each party to the proceedings
and note the date of service in the docket. See App.R. 30.
Mark C. Miller, Judge
William R. Zimmerman, Judge
Juergen A. Waldick, Judge
DATED: /jlm
-9-