deficient. The PCR court did not make any findings or conclusions directly on this point. However, the court did find that the mitigation specialist, Barb Bumpus, had never worked on a capital case and was not qualified to do so; the Legal Defender’s Office restricted counsel’s ability to perform mitigation; and counsel had no supervisory authority over mitigation personnel. ¶ 60 Although both Shriver and Sinclair testified that the mitigation specialist was unqualified, defendants do not have a stand-alone right to a mitigation specialist. See Phillips v, Bradshaw, 607 F.3d 199, 207-08 (6th Cir. 2010) (“[H]iring a mitigation specialist in a capital case is not a requirement of effective assistance of counsel.”); State v. Herring, 142 Ohio St.3d 165, 28 N.E.3d 1217, 1239 ¶ 113 (2014) (<HOLDING>). To determine whether counsel provided
recognizing constitutional right to effective counsel holding right to testify was federal constitutional right holding defendant had no constitutional right to a mitigation specialist or a right to an effective one holding that a defendant has a constitutional right to counsel as a matter of right on direct appeal holding that a defendant who sought to receive the death penalty had the right to refuse to present mitigation evidence