State v. Bryant

Citations

• 2026 Ohio 559

Syllabus

Ineffective assistance of counsel; self-defense; mental-health evaluations; competency to stand trial; sanity at the time of the act; prejudice; expert. Trial counsel rendered ineffective assistance when counsel failed to revisit the trial court's referral for an examination for sanity at the time of the act after the defendant was restored to competency. Counsel's strategic decision to advance a self-defense argument at trial necessarily required a complete investigation into the defendant's mental-health condition, including ensuring all evaluations were completed and potentially retaining an expert.