Myers was convicted in 2014 of murdering a childhood friend, Justin Back, 18, of Wayne Twp., and sentenced to death. Back was about to join the U.S. Navy.
Myers was the youngest person on Ohio’s Death Row at the time.
Timothy Mosley, the other Clayton man charged in the case, entered a plea to life in prison without parole and cooperated with prosecutors.
RELATED: Local teen youngest on Ohio’s Death Row
“As can be seen from the meritorious issues that were not presented in this case, appellate counsel were prejudicially ineffective,” Orrick said in the motion.
Orrick urged the court to reopen the case because direct-appeal counsel failed to include a complete transcript “of all the proceedings against him.”
In addition, Orrick claims “direct appeal counsel’s failure to reconstruct the trial court’s repeated discussions with counsel that took place off the record.”
Co-defendant pleads guilty in Warren County death penalty case
Orrick claims Myers’ trial lawyers should have moved for suppression of evidence against Myers on his cellphone, eliminated two jurors “who had been exposed to pretrial publicity” and renewed their request for a change of venue and continuance.
In addition, Orrick claims Myers’ trial lawyers should have called more witnesses about his mental health, helped him prepare his statement and “properly” challenged “Mosley’s purported notebook.”
RELATED: Notebook surfaces in Warren County death penalty case
RELATED: Clayton man step closer to execution
Myers’ trial lawyers, Greg Howard and John Kaspar, did contest the use of the notebook, found eight months after the alleged murder.
Lawyer Timothy McKenna argued for Myers’ life before the Ohio Supreme Court.
Myers is being held in the Chillicothe Correctional Institution.