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Court ordered to grant competency hearing in armed robbery case

Legal News Reporter

Published: January 14, 2021

A Summit County trial court violated a defendant’s due process rights when it determined he committed the charged offenses without giving him an opportunity to be heard on that issue, according to the 9th District Court of Appeals.
William Coffman was indicted in October 2018 on one count of aggravated robbery with a firearm specification. He pleaded not guilty by reason of insanity and requested an evaluation of his mental condition and competency to stand trial.
The trial court ordered an evaluation and determined Coffman was not capable of understanding the nature of the proceedings against him and assisting in his defense. Coffman was ordered to undergo treatment at Northcoast Behavioral Healthcare System.
One year later, Dr. Susan Hatters-Freedman from Northcoast filed a written report stating there was not a substantial probability Coffman would become capable of standing trial. The parties stipulated to the report.
The trial court issued a journal entry finding that based on the report, the evidence before the court, and the stipulation of the parties, there was not a substantial probability Coffman would become capable of understanding the nature and objective of the proceedings against him or become capable of assisting in his defense.
After a hearing, the trial court concluded it would maintain jurisdiction over Coffman for 14 years.
On appeal, Coffman argued the trial court violated his due process rights by failing to allow him to confront the evidence.
The state alleged that instead of asserting his right to an evidentiary hearing, he assented to the trial court’s order to file briefs on the issue of his confinement.
Both parties filed briefs on the issue of Coffman’s confinement.
“While the state argued the trial court was required to retain jurisdiction over the matter, it did not address whether there was clear and convincing evidence that Coffman committed the offense of aggravated robbery,” 9th District Judge Donna J. Carr wrote in her 3-0 opinion. “In response, Coffman maintained that the probate court was best equipped to handle this matter. Coffman also underscored that the state had not addressed the issue of whether he committed the charged offense and further stressed that ‘there has been no determination by the court finding that [he] committed the [charged offense].’
“On April 3, 2020, the trial court issued a journal entry indicating that it would retain jurisdiction over defendant for a period of 14 years. The trial court further ordered that Coffman would be placed at Northcoast as that was the least restrictive alternative available. The trial court made a number of findings in support of its decision, including that ‘[t]here is clear and convincing evidence that [Coffman] committed the offense(s) with which [he] is charged.’
“Under these circumstances we are compelled to sustain Coffman’s … assignment of error.”
The appellate panel cited Addington v. Texas, 441 U.S. 418, 425 (1979), which stated, “A civil commitment for any purpose is a significant deprivation of liberty and due-process protections must be afforded to a person facing involuntary commitment.”
Carr noted there was no evidence presented at the Dec. 30, 2019 hearing that would have allowed the trial court to form a basis for its conclusion there was clear and convincing evidence that he committed the offense.
“While Coffman stipulated to the report submitted by Dr. Hatters-Freedman, he argued that the matter should be transferred to the probate court for further proceedings,” the appellate judge wrote. “He did not stipulate that there was clear and convincing evidence that he committed aggravated robbery as charged in the indictment. In Coffman’s brief addressing the issue of his confinement, he reiterated that the state had not established by clear and convincing evidence that he had committed the charged offense. Accordingly, the trial court’s conclusion to that end in its April 3, 2020 journal entry violated Coffman’s due process rights as he was entitled to a hearing on that issue pursuant to R.C. 2945.39(A)(2)(a).”
Since the panel ordered the matter be remanded for a hearing, it found Coffman’s argument that the trial court committed reversible error in finding he was a mentally ill person subject to court order to be moot.
Appellate judges Julie Ann Schafer and Jennifer Hensal concurred. The case is cited State v. Coffman, 2020-Ohio-6855.