John M. Stuard Reprimanded
Court
Trumbull County Court of Common Pleas
Location
Warren, OH
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Sixth Circuit Vacates Death Sentence Based On Judge's Bias, Misconduct
Defender Services Office, Training Division
Published: August 17, 2024
John M. Stuard, a Trumbull County Court of Common Pleas judge, was publicly reprimanded by the Ohio Supreme Court's Disciplinary Counsel for violating two canons of the state's judicial code of conduct after he tasked the prosecutor in a capital case, Nathaniel Jackson's, with drafting the sentencing opinion using the judge's own notes — rather than independently deciding and writing the sentence himself.
The U.S. Court of Appeals for the Sixth Circuit later went further, ruling in Jackson v. Cool that Stuard was unconstitutionally biased and had improperly denied Jackson the opportunity to present additional mitigating evidence, vacating the death sentence and granting habeas relief. Despite the disciplinary reprimand and years of Jackson's own motions for relief, Stuard refused to recuse himself or grant a new sentencing hearing, and ultimately resentenced Jackson to death himself, in an opinion the courts found was nearly identical to the original one the prosecutor had ghostwritten.
Submitted: September 11, 2026
The U.S. Court of Appeals for the Sixth Circuit later went further, ruling in Jackson v. Cool that Stuard was unconstitutionally biased and had improperly denied Jackson the opportunity to present additional mitigating evidence, vacating the death sentence and granting habeas relief. Despite the disciplinary reprimand and years of Jackson's own motions for relief, Stuard refused to recuse himself or grant a new sentencing hearing, and ultimately resentenced Jackson to death himself, in an opinion the courts found was nearly identical to the original one the prosecutor had ghostwritten.
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