The Akron Legal News

Life sentence affirmed for murderer who wanted death penalty

ANNIE YAMSON
Special to the Legal News
Published: February 28, 2014

Recently the 8th District Court of Appeals overruled an appeal from Steven Combs who was found guilty of aggravated murder, aggravated burglary, felonious assault, kidnapping and having a weapon under disability in the Cuyahoga County Court of Common Pleas.

A three-judge appellate panel found no merit to Combs’ nine assignments of error including claims that he did not knowingly enter his guilty plea or waive his right to a jury trial.

Combs was seeking the death penalty for the murder of Jeffrey Mechling on Aug. 2, 2011.

The Cuyahoga County Grand Jury indicted Combs on nine counts, all of which contained firearm and repeat violent offender specifications as well as a notice of prior conviction.

Combs had a history of violent crimes, including an unrelated arson.

Following competency evaluations, doctors concluded that Combs was competent to stand trial however, he entered a guilty plea to all counts of his indictment.

Because the charges carried the possibility of a death sentence, a hearing was conducted before a three-judge panel in order to determine Combs’ guilt.

According to case summary and hearing testimony, Combs cut through a screen door and entered the residence of Mechling, who was asleep in his bed beside his girlfriend, Dawn Kalal.

Kalal was awoken by the sound of gunshots and turned around to see Mechling bleeding from the face and head.

She saw a person, later determined to be Combs, standing over Mechling wearing a Ghostface mask from the movie “Scream.”

Combs then put the gun in his waistband and pulled out a knife with a blade over a foot long and began brutally stabbing Mechling.

An autopsy revealed that Mechling died from the stab wounds and not the gunshots to the head.

Combs then pulled Kalal out of the bed and put the knife to her neck.

He threatened to kill her and her child if she told anyone about the incident.

He then forced her into the kitchen where he showed her that he took money from her purse and went through Mechling’s wallet to make it look like a robbery.

Combs then took Kalal’s cell phone and took a picture of her face. He returned to the bedroom, put the knife through Mechling’s neck, and took a picture with the phone.

Joshua Nally testified that he and Combs had been neighbors for several years. After the murder, Nally and his wife invited Combs and his girlfriend, Karen Fleming over for dinner.

At the dinner, Combs told Nally that he had killed a man he was angry with and described how he had entered the home, what he wore and how he stabbed Mechling with what he called a “pig sticker.”

Fleming testified that, prior to the murder, she had been in an argument with Mechling at his home. That same night, she got in a fight with Combs and he hog-tied her to prevent her from leaving.

The next morning, Fleming went to Combs’ house and observed him place a “Scream” mask, gun, pink cell phone and a marshal arts jacket in a black garbage bag.

Fleming saw Combs give the bag and a large knife to Vincent Labriola, a friend of Combs’ and his co-defendant in the arson case.

Combs eventually admitted to Fleming that he had killed Mechling after she saw news of the murder on TV.

Labriola testified that Combs gave him the tools he used to kill Mechling and that he had disposed of them because Combs told him that he used the items to “kill a Puerto Rican.”

Labriola threw the clothing and mask into a garbage can in Summit county. He told the court that he threw the gun into a swamp but that he kept the sword because it was too big to dispose of.

He handed the sword over to the police after they contacted him and indicted that he could be implicated in the murder.

DNA analysts for the Cuyahoga County Medical Examiner’s office testified that Combs’ DNA could not be excluded as a possible contributor to DNA recovered from the scene of the murder.

Police also concluded that the sword matched the types of stab wounds suffered by Mechling.

The three-judge panel determined that Combs was guilty of each charge beyond a reasonable doubt.

Despite the fact the Combs prohibited his attorneys from presenting mitigating evidence in an attempt to receive the death penalty, the trial court sentenced him to life in prison without the possibility of parole.

On appeal, Combs argued that his guilty pleas were not knowing, voluntary and intelligent. He contended that the court failed to fully explain his rights.

“He admits that the court advised him of his constitutional rights, but failed to have a dialogue with him to explain the rights,” wrote Judge Patricia Ann Blackmon on behalf of the court of appeals. “Specifically, the fact that his guilty plea did not mean he would automatically get the death penalty.”

After reviewing the transcript, the appellate panel found that the trial court engaged Combs in a dialogue several times regarding his possible sentence, including the possibility of life in prison.

Combs also claimed that he did not knowingly and voluntarily waive his right to a trial by jury.

According to him, he was not told that the jury could only make a recommendation of death or that a panel of judges could block his wish to receive the death penalty.

“Our review of the record reveals that the trial court had extensive conversations with Combs regarding how the death penalty would be determined, both if he had a jury trial or pled before a three-judge panel,” wrote Judge Blackmon. “Although the court admittedly failed to tell Combs that the jury could only recommend the death penalty, we do not see how this affected the validity of his jury waiver.”

The transcript of the proceedings, Judge Blackmon noted, indicated that the court did inform Combs that under either scenario, he was not guaranteed to get the death penalty but could instead receive life in prison.

Judge Blackmon went on to overrule the remainder of Combs’ arguments and the judgment of the Cuyahoga County court was ultimately affirmed.

Judges Mary Boyle and Eileen A. Gallagher concurred.

The case is cited State v. Combs, 2014-Ohio-497.

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