State v. Lowell

Citations

• 179 N.E.3d 676
• 2021 Ohio 3098

Syllabus

Not guilty by reason of insanity, consecutive commitments, R.C. 2945.40, R.C. 2945.401(J)(1)(b). Trial court erred in running civil commitments consecutively under R.C. 2945.401(J) where the plain language of the statute does not provide for consecutive civil commitments. R.C. 2945.401(J) defines the length of the trial court's jurisdiction not the term of the insanity acquittee's commitment. An insanity acquittee's commitment is solely defined by whether they remain a mentally ill person subject to court order as defined in R.C. 5122.01(B). Further, R.C. 2929.14(C)(4) has no application in the civil commitment context.