Judge Rejects Death Row Inmate's Intellectual Disability Claim

Trumbull County judge rules evidence does not support Andre 'Kokomo' Williams' Atkins claim

Published on Feb. 4, 2026

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Trumbull County Common Pleas Judge Sean J. O'Brien has denied death row inmate Andre 'Kokomo' Williams' appeal for relief from the death penalty due to an intellectual disability claim, also known as an Atkins claim. Williams was convicted and sentenced to death in 1989 for the murder of George Melnick and the attempted rape and attempted aggravated murder of Melnick's wife, Kathryn.

Why it matters

The U.S. Supreme Court ruled in 2002 that those with intellectual disabilities cannot be executed. Williams' case is part of a broader legal debate around the application of the Atkins v. Virginia decision and determining what constitutes an intellectual disability that would preclude the death penalty.

The details

Judge O'Brien cited 20 different evaluators from 1989 to 2015 who did not find Williams intellectually disabled, versus only four hired by Williams' attorneys who found he was disabled. O'Brien found Williams provided 'too many inconsistent and contradictory statements' for professionals to agree on basic facts, and that he has demonstrated 'he was spoiled and lazy growing up; has anger issues; has a sense of entitlement; has a prior head injury; has abused drugs and alcohol and has continuously lied.' The judge also noted Williams has extensive knowledge, can adequately converse, and does not have significant deficits in problem-solving.

  • In 2002, the U.S. Supreme Court decided in Atkins vs. Virginia that those with intellectual disability cannot be executed.
  • In 1989, Williams was convicted and sentenced to death for the murder of George Melnick and the attempted rape and attempted aggravated murder of Melnick's wife, Kathryn.
  • In 2019, Judge W. Wyatt McKay held a nine-day hearing and again found Williams was not intellectually disabled.
  • In December 2023, the 11th District Court of Appeals reversed McKay's decision, instructing the trial court to reconsider Williams' argument due to a change in the law.
  • Last month, Judge O'Brien rendered his decision rejecting Williams' Atkins claim.

The players

Andre 'Kokomo' Williams

A 56-year-old death row inmate convicted in 1989 for the murder of George Melnick and the attempted rape and attempted aggravated murder of Melnick's wife, Kathryn.

Sean J. O'Brien

The Trumbull County Common Pleas Judge who denied Williams' appeal for relief from the death penalty due to an intellectual disability claim.

George Melnick

The victim of the 1988 murder for which Williams was convicted and sentenced to death.

Kathryn Melnick

The victim of the attempted rape and attempted aggravated murder for which Williams was convicted and sentenced to death.

Christopher Daniel

A co-defendant who attacked Kathryn Melnick with a cinder block, severely beating her and permanently injuring her, including a total loss of vision.

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What they’re saying

“The defendant has demonstrated that he was spoiled and lazy growing up; has anger issues; has a sense of entitlement; has a prior head injury; has abused drugs and alcohol and has continuously lied.”

— Sean J. O'Brien, Trumbull County Common Pleas Judge (tribtoday.com)

“Trumbull County Prosecutor Dennis Watkins praised O'Brien's 102-page 'common sense' decision as judicially sound, and which now again found Williams not to be suffering any disqualifying disability and therefore was properly sentenced to death by McKay.”

— Dennis Watkins, Trumbull County Prosecutor (tribtoday.com)

What’s next

The judge's decision affirms Williams' death sentence, which will now likely move forward through the appeals process.

The takeaway

This case highlights the ongoing legal debate around determining intellectual disability in death penalty cases, with judges weighing extensive psychological evaluations and evidence to make these complex determinations.