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Criminal Law Casebook
Franklin County Criminal Law Casebook
Reproduced with permission from:
David L. Strait
Franklin County Public Defender Office
Last Updated 3/3/2015
Criminal Rule 11(C) and (D) -- permit court to refuse to accept guilty or no contest plea in both felony and misdemeanor cases.
Criminal Rule 11(F) -- requires plea agreement in a felony case be stated on the record.
Criminal Rule 11(H) -- when court refuses to accept guilty or no contest plea, it is to enter not guilty plea on behalf of the defendant.
-- Nolle prosequi may not be entered without leave of the court.
State v. Gilbert
, ___ Ohio St.3d ___,
, ___ N.E.3d ___-- Once a defendant has been sentenced by a trial court, that court does not have jurisdiction to entertain a motion by the state to vacate the defendant’s guilty plea and sentence based upon the defendant’s alleged violation of a plea agreement.
Appellant's Merit Brief
Appellee's Merit Brief
State v. Fitzgerald
, 188 Ohio App. 3d 701,
– A judge’s blanket policy of not accepting plea bargains once a trial date has been set constitutes an abuse of discretion.
State v. Aponte
(2001), 145 Ohio App. 3d 607 -- "Defendant's agreement" provided for the defendant to plead guilty to first degree felonies, then if he fulfilled his obligations the pleas could be withdrawn and pleas entered to less serious offenses. Since the court, not the prosecutor, had the authority to permit withdrawal of guilty pleas, the plea bargain was illusory and unenforceable. Pleas were voidable. Trial and appellate counsel were ineffective. Application of
would be unjust.
State v. Georgakopoulos
, 152 Ohio App. 3d 288,
-- The court is not required to impose the sentence jointly recommended by the prosecution and defense as part of a plea bargain where it was not a party to that agreement.
Weatherford v. Bursey
(1977), 429 U.S. 545, 560-561 -- There is not constitutional right to a plea bargain. Prosecutor need not do so if he prefers to go to trial.
Akron v. Ragsdale
(1978), 61 Ohio App. 2d 107, 109 -- The trial court may reject a plea bargain if it within the sound exercise of its discretion to do so.
State v. Ridgeway
(1990), 66 Ohio App. 3d 270.
State v. Hughes
(December 30, 1982), Franklin Co. App. No. 82AP-695, unreported (1982 Opinions 4027) -- When there has been an express plea bargain agreement entered into, the court may accept or reject the agreement, but it is not the court's prerogative to change the terms of the plea bargain without the consent of both parties.
State v. Menucci
(1986), 33 Ohio Misc. 2d 15 -- While the trial court has the final authority to accept or reject a plea bargain, it should not summarily reject the prosecutions recommendation in a plea bargain. Also see
Akron v. Ragsdale
(1978), 61 Ohio App. 2d 107, 109.
North Carolina v. Alford
(1970), 400 U.S. 25 -- A guilty plea may be voluntary, knowing and understanding, where entered to avoid a greater penalty, though the defendant denies guilt.
State v. Darmour
(1987), 38 Ohio App. 3d 160, 161 -- "No abuse of discretion is present when the trial court forewarns a defendant that it will not consider itself bound by any sentencing agreement and defendant fails to change his plea."
State v. Childress
(1993), 91 Ohio App. 3d 258 -- As a part of a plea bargain, an indictment may be amended to add a physical harm specification pursuant to
, thus requiring an indeterminate sentence, without submitting the specification to a grand jury.
State v. Dilley
(1989), 47 Ohio St. 3d 20, distinguished. Also see
State v. Fryling
(1992), 85 Ohio App. 3d 557.
United States, ex rel. Caruso, v. Zelinski
(3rd Cir. 1982), 689 F. 2d 435, 438 -- Counsel's failure to communicate plea offer to defendant was a gross deviation from accepted professional standards and may be the basis for a claim of ineffective assistance of counsel.
Consequences when no Agreement is Reached
State v. Cardinal
, Franklin App. Nos. 04AP-229 through 233,
-- Sua sponte order of competency evaluation was not warranted. Defense counsel did not question competency and the defendant's behavior in court was not erratic. Grounds cited after the fact by the prosecutor are commonplace. Evaluation appears to have been a stall to provide more time to work out a plea bargain in a case involving numerous charges.
State v. Tillman
(1990), 66 Ohio App. 3d 464, 467-468 -- It is improper for a prosecutor to assert in closing argument that he refused to plea bargain with the defendant.
State v. Davis
(1980), 70 Ohio App. 2d 48 -- After plea bargaining broke down and case proceeded to trial, held that court properly kept out testimony that defendant had not pleaded guilty be cause he was not guilty.
State v. Mitchell
(1997), 117 Ohio App. 3d 703 -- Defendant rejected plea bargain and received a substantially longer sentence after being convicted at trial. Though some aspects of the court's action may be criticized, there is no presumption of vindictiveness in these circumstances, and the defendant's record and attitude following conviction reflected poorly on his "prospects for rehabilitation." See dissent.
State v. Robertson
(1995), 108 Ohio App. 3d 173 -- The presumption of vindictiveness which applies when a defendant has won on appeal, then been convicted when retried and given a greater sentence, does not apply when the greater sentence follows an appeal from a guilty plea, and conviction at trial.
Role of the Judge
State v. Sawyer
, 183 Ohio App. 3d 65,
– Judge took a very active role in promoting a plea bargain that netted the defendant maximum consecutive sentences in a plea to aggravated assault, reduced from felonious assault. Negotiations were already underway, the judge is said to have been seeking clarification, and his conduct is not deemed coercive to the extent the defendant would have feared she could not receive a fair trial.
State v. Stafford
, 158 Ohio App. 3d 509,
-- After opening statements the judge pressed the defendant to plead guilty, saying even though the facts merited more time, he would probably be given an eleven year sentence. If convicted he would probably get twenty-three years. Upon conviction, the sentence was twenty years. Reversed. It was a denial of due process to punish the defendant for asserting his right to jury trial. The record demonstrates actual vindictiveness, or at least the state has failed to overcome the presumption of vindictiveness.
In re Steinmetz
, Montgomery App. No. 19254,
-- Magistrate coaxed an admission by threatening stacked sentences if a juvenile wasted the court's time and went to trial and there were multiple convictions, versus six months on an admission. Coercion found even absent a statement by the juvenile that he felt coerced, since the record indicates he came to court intending to reject the state's plea offer.
Columbus v. Bee
(1979), 67 Ohio App. 2d 65 -- When the judge has taken an active role in plea bargaining, and a tentative sentence has been discussed, if negotiations break down and the case goes to trial and a harsher sentence is imposed in the end, the record must show that improper weight was not given to the defendant's failure to accept the plea bargain and that the sentence was based solely on the facts of the case and the defendant's individual history.
State v. Byrd
(1980), 63 Ohio St. 2d 288, 293-294 -- "(W)e hold that a trial judge's participation in the plea bargaining process must be carefully scrutinized to determine if the judge's intervention affected the voluntariness of the defendant's guilty plea. Ordinarily, if the judge's active conduct could lead a defendant to believe he cannot get a fair trial because the judge thinks that a trial is a futile exercise or that the judge would be biased against him at trial, the plea should be held to be involuntary and void under the Fifth Amendment and Section 10, Article I of the Ohio Constitution." Also see
State v. Ball
(1990), 66 Ohio App. 3d 224.
State v. Walker
(1989), 61 Ohio App. 3d 768 -- It was improper for a judge to encourage the defendant to plead guilty by telling him trial was futile because of the number of his prior convictions and weakness of his defense.
State v. Harper
(1988), 47 Ohio App. 3d 109 -- Headnote 1: "In deciding whether to accept a no contest plea, a trial court abuses its discretion by considering such inappropriate matters as plea bargaining and defendant's expressed desire to preserve his right to appeal; by repeatedly advising defendant that any plea agreement must be based upon a guilty plea, the court adversely affects the voluntariness of defendant's eventual decision to plead guilty."
United States, ex rel. Elksnis, v. Gilligan
(S.D.N.Y. 1966), 256 F. Supp. 244 -- "The unequal positions of the judge and the accused...at once raise a question of fundamental fairness. When a judge becomes a participant in plea bargaining he brings to bear the full force and majesty of his office.... A defendant needs no reminder that if he rejects the proposal, stands upon his right to trial and is convicted, he faces a significantly longer sentence.... Intentionally or otherwise, and no matter how well motivated the judge may be, the accused is subjected to a subtle but powerful influence."
State v. Filchock
(1996), 116 Ohio App. 3d 572 -- Court erred in accepting no contest plea to OMVI and other charges without informing the defendant of the effect of his plea, apprising him of his right to counsel and obtaining a waiver of counsel, and making certain that the plea was knowing and voluntary in the constitutional sense. Judge faulted for having proposed the plea bargain, promised what sentence he would give, and implied things would come out worse otherwise. Due process violation found. Also see
State v. Filchock
(1998), 126 Ohio App. 3d 66.
State v. Gilroy
, 195 Ohio App. 3d 173,
– Defendant with a long record was promised probation if she (1) went for a PSI, (2) retuned for sentencing, and (3) stayed out of trouble until then. During the time between hearings she tested positive for marijuana and cocaine. Second condition wasn’t met, thus the court property imposed a prison sentence.
State v. Arde
, 190 Ohio App. 3d 196,
– Financial manger embezzled almost $350,000. Plea agreement was a three year sentence provided she showed up for reporting dates and sentencing and stayed out of trouble. A week before sentencing the judge scheduled a hearing and asked where the embezzled money had gone. Defendant responded that her husband was an addict who had bounced checks she paid back, and that money was spent on living expenses. Judge claimed the failure to be more specific breached he plea deal and gave her nine years. Reversed. Applying contract principles, greater candor was not a part of the agreement, and the defendant had met all of the other terms.
State v. Dumas
, Fairfield App. No. 02CA60,
-- A county prosecutor is an agent of the state of Ohio only with respect to crimes committed in the home county. The Franklin County Prosecutor's agreement to limit prosecution did not bind the Fairfield County prosecutor as to a crime the defendant confessed to committing in that county.
State v. Roberts
(2001), 141 Ohio App. 3d 578 -- Student who agreed to be a snitch won a new trial after state called him to testify, which it was claimed ratified the initial agreement. Reversed as motion for a new trial was not timely. Also see
State v. Roberts
, Wood App. Nos. WD-03-001. WD-02-66,
where the award of new trial on remand is affirmed. ¶ 11: "...(W)hen a motion for new trial is granted, we conclude that it is within the trial court's discretion whether or not to reopen factual determinations which have already been fully litigated."
State v. Burks
, Franklin App. No. 04AP-531,
-- Court did not initially release defendant on shock probation as agreed, then balked at outright release when it turned out he was ineligible for a CBCF placement the court deemed necessary. Specific performance was impossible. Defendant should be allowed to withdraw his guilty plea.
Santobello v. New York
(1971), 404 U.S. 257 -- When prosecutor has failed to live up to his end of plea bargain (here to make no recommendation as to sentence) available remedies are specific performance of the original agreement or to allow the defendant to vacate his plea. Case stands for the principle that the prosecutor must negotiate plea bargains in good faith.
Mabry v. Johnson
(1984), 467 U.S. 504 -- Though prosecution may have reneged on initial plea offer which defendant had agreed to, defendant may not be able to have vacated subsequent agreement if it was knowingly and voluntarily entered into.
State v. Johnson
(June 23, 1981), Franklin Co. App. No. 80AP-449, unreported (1981 Opinions 1807) -- Once plea offer had been accepted by the defendant, it could not be withdrawn by the prosecutor, though it was still subject to acceptance by the court. Also see
State v. Reynolds
(February 27, 1973), Franklin Co. App No. 72AP-287, unreported (1973 Opinions 477, 483)
State v. Carpenter
(1993, 68 Ohio St. 3d 59 -- Syllabus: "The state cannot indict a defendant for murder after the court has accepted a negotiated guilty plea to a lesser offense and the victim later dies of injuries sustained in the crime, unless the state expressly reserves the right to file additional charges on the record at the time of the defendant's plea."
State v. Burchfield
(1997), 118 Ohio App. 3d 53 -- Parties seemingly reached a plea bargain during early phase of prosecution in Municipal Court, but it was not enforceable because it was not put into written form, signed by the parties, and because it was not stated on the record in open court as required by Crim. R. 11(F). Had these things been done, the agreement between the defendants and the city-designated special prosecutor would have been enforceable notwithstanding an intervening indictment obtained by the county prosecutor.
State v. Barnett
(1998), 124 Ohio App. 3d 746 -- Defendant maintained plea bargain in Warren County bound the Montgomery County Prosecutor, barring prosecution on additional charges. (1)
State v. Urvan
(1982), 4 Ohio App. 3d 151, is limited to situations where different counties attempt to prosecute allied offenses of similar import. (2) Though county prosecutors all represent the State of Ohio, they do so only within their own locale, and do not act under supervision of a broader authority such as the state Attorney General of the federal Department of Justice. Whatever the Warren County Prosecutor may have agreed to was done without apparent authority to bind the Montgomery County Prosecutor.
State v. Matthews
(1982), 8 Ohio App. 3d 145, 146 -- "Police officers have no authority to enter into plea-bargain negotiations with a person accused of a crime, and such a plea-bargain agreement is unenforceable and of no effect except upon motion to suppress evidence if wrongfully obtained by promises made during the improper plea bargaining, which is later repudiated by the prosecutor who has the authority to enter into plea bargaining, subject to the ultimate review and approval by the court." Also see
State v. Cramer
(December 21, 1982), Franklin Co. App. No. 82AP-458, unreported (1982 Opinions 3845, 3849-3850).
State v. Butts
(1996), 112 Ohio App. 3d 683 -- After guilty verdict, defendant agreed not to appeal in exchange for dismissal of a specification alleging a prior aggravated felony conviction. The right to appeal may be voluntarily waived. The agreement could be specifically enforced.
In re Leonhardt
(1993), 62 Ohio Misc. 2d 783 -- Federal and state due process guarantees bar the refiling of a charge in juvenile court which has previously been dismissed pursuant to a plea agreement.
Failure to Fulfill Obligations
State v. Ross
, 179 Ohio App. 3d 48,
– As a part of plea bargain prosecutor agreed to stand mute at sentencing. Agreement was not breeched by making a statement at the sentencing hearing that at the time the agreement was struck the state was not aware of offenses the defendant was alleged to have committed after that date in a different county.
State v. Bethel
, 110 Ohio St. 3d 416,
-- In a capital homicide a plea agreement involved a proffer inculpating the defendant and his agreement to testify against the codefendant. He failed to do so. Court applies contract law to sort out language of the agreement to determine whether statement could be used against the defendant at his own trial. Court cites a 1911 civil case for the proposition that contracts are to be construed to give effect to every provision therein. Death penalty affirmed.
State v. Thompson
, Adams App. No. 03 CA 766,
-- A plea bargain is contractual in nature, and was breached when the prosecutor followed to follow through on his promise to recommend a two-year sentence. It is within the discretion of the trial court whether to require specific enforcement of the agreement or withdrawal of the plea, but it must order one or the other.
State v. Scheer
, 158 Ohio App. 3d 432,
-- By silence at the sentencing hearing, the prosecutor breached the agreement to recommend a one year sentence if the judge did not grant community control. But the error was harmless in view of the judge's recitation of the agreement at the time the plea was entered.
State v. Lewis
, Allen Case No. 1-02-10,
-- Court acted within its discretion in overruling motion to withdraw guilty plea made before sentencing. But prosecutor breached agreement to stand mute at sentencing except as to restitution by stating that the confidential informant had been assaulted by the defendant. Agreement to stand mute was not limited to not recommending a sentence. Remanded to trial court to fashion a remedy, suggestions being a new sentencing hearing in front of a different judge, or further consideration of motion to withdraw guilty plea.
State v. Vega
, Hamilton App. No. C-020486,
-- Defendant paid for construction equipment auctioned by the county with a check on a closed account. Plea bargain involved reduction of charges, payment, return of seized machinery to the defendant, and a recommendation of community control. Prosecutor found in breech as equipment was sold by the county though defendant eventually came up with the money. Remedy is remand with instructions defendant be allowed to withdraw his plea.
State v. Patrick
, 163 Ohio App. 3d 666,
, ¶23-29 -- Agreement was that the defendant would get five years, but the court gave six. Remedy is remand for resentencing. Though the defendant also sought to withdraw his guilty pleas, the failure to impose the agreed upon sentence did not invalidate the pleas.
State v. Price
, Hamilton App. No. C-030262,
, ¶ 1 -- "A trial court is not bound by an agreed sentence where a defendant absconds before sentence and, after his arrest, the court overrules his motion to withdraw his guilty plea."
State v. Adkins
, 161 Ohio App. 3d 114,
-- Defendant claimed the state breached its side of the plea bargain which would have led to placement in a treatment program. The court held defendant was in breach by failing to present himself for evaluation or appear for hearings. At ¶9: Appearance at all scheduled court dates is an implied covenant in any plea agreement.
State v. Yarborough
, 165 Ohio App. 3d 276,
-- Agreement was kept insofar as the aggregate sentence was four years, but it was breached with respect to the promise of one year concurrent mandatory sentences on some of the charges, Since this had an impact on eligibility for judicial release, sentence is vacated.
State v. Walton
(1981), 2 Ohio App. 3d 117 -- When a defendant declines to testify against a codefendant, as agreed in plea bargaining, and moves to withdraw the guilty plea, the court abuses its discretion by allowing the plea to stand and imposing a sentence greater than that agreed to. The court's options are to impose sentence according to the agreement or to allow withdrawal of the plea.
Ricketts v. Adamson
(1987), 483 U.S. 1 -- No double jeopardy violation found in the following circumstances: Defendant pleaded guilty to second-degree murder in exchange for agreement to testify against codefendants, did so and was sentenced. Codefendants' conviction was reversed and defendant refused to testify at their retrial. As a result, his conviction was vacated and he was tried and convicted of first degree murder.
Columbus v. Wolfinger
(February 8, 1996), Franklin Co. App. No. 95APC07-859, unreported (1996 Opinions 439) -- Pursuant to a plea bargain, defendant pleaded guilty to a defective complaint, which failed to allege a culpable mental state. Since by appealing, and by prevailing rendering the plea void, the defendant did not perform his part of the agreement, upon remand, the original charges may be reinstated.
United States v. Benchimol
(1985), 471 U.S. 453 -- U.S. Attorney's failure to explain reasons for agreed recommendation of probation with restitution, or to make that recommendation "enthusiastically" did not breach plea agreement.
State v. Murnahan
(1996), 117 Ohio App. 3d 71 -- Prosecutor breached agreement to stand silent at sentencing by asking for the maximum. Though this conduct was reprehensible, record indicates sentencing decision was based on the judge's own assessment. See dissent.
State v. Jeffries
, 119 Ohio St. 3d 265,
– Prior to plea negotiations the defendant took and passed a polygraph. As part of a cooperation agreement with the prosecutor, the results of the test were made known and a copy of her statement turned over. She failed a subsequent polygraph and the deal fell apart. Nonetheless, her statement to the first polygraphist was admissible since it was made prior to the commencement of plea negotiations. Syllabus: "Statements that were not made in the course of plea discussions are not protected by Evid. R. 410, even if the statements were later provided to the state in the course of plea discussions."
State v. Rohrbach
, 178 Ohio App. 3d 211 – As a part of a plea bargain a count alleging breaking and entering was amended to F-5 receiving stolen property. The defendant did not object, but reversed as plain error because the amendment violated the constitutional right to indictment by a grand jury. Court noted that the plea agreement failed to include a recitation that the defendant waived his right to indictment by a grand jury. Reversed by
State v. Rohrbaugh
, 126 Ohio St. 3d 421,
– Syllabus: “A defendant may plead guilty to an indictment that was amended to change the name and identity of the charged crime when the defendant is represented by counsel, has bargained for the amendment, and is not prejudiced by the change.”
State v. Chapman
, 190 Ohio App. 3d 528,
, ¶19-21 – At the first trial a codefendant testified the prosecutor offered to reduce his sentence from 51 to 13 years if his testimony secured a conviction. The 9th District reversed as this amounted to an invitation o perjury. Codefendant testified again at the retrial. This time a copy of his plea agreement was admitted, showing it did not make benefits contingent on conviction. Assignment of error overruled. Earlier case was
State v. Chapman
, 9th Dist. No. 07CA009161,
State v. Perkins
, 191 Ohio App. 3d 263,
– Fight between cement contractor and site foreman was originally indicted as aggravated assault, but before trial the prosecutor advised defense counsel that the case would be reindicted if a plea wasn’t entered to the aggravated assault. Ultimately the defendant received the maximum sentence for felonious assault. On appeal the defendant claimed vindictive prosecution, relying on a summary judgment reversal in a postconviction action appeal. Court is of the view the state need not begin with a comprehensive indictment and that it is common for a prosecutor’s understanding of a case to change with preparation for trial.
Layne v. Ohio Adult Parole Authority
, 97 Ohio St. 3d 456,
-- In the determination of parole eligibility, defendants are entitled to the benefit of the plea bargains they struck. APA rating system looked to original charges instead. APA still retains discretion to consider relevant circumstances in making ultimate decision. Syllabus: "In any parole determination involving indeterminate sentencing, the Adult Parole Authority must assign an inmate the offense category score that corresponds to the offense or offenses of conviction."
Ankrom v. Hageman
, Franklin App. Nos. 04AP-984 et. seq.,
-- Broad relief granted pre-S.B. 2 inmates in challenge of the guideline system adopted by the APA which frequently led to a range of months to be served before parole that was well beyond the minimum sentence. Adherence to the guidelines meant for many there was not meaningful consideration of parole upon serving the minimum sentence, among other things violating the contractual basis of the plea agreements struck when an earlier system, the "matrix," was is use.
Ankrom v. Hageman
, 118 Ohio Misc. 2d 226,
State v. Stephens
, Hamilton App. No. C-020683,
-- The remedy for a
violation is a declaratory judgment action against the Adult Parole Authority and the county prosecutor, not a motion to withdraw the guilty plea. Also see
State v. Davis
, 158 Ohio App. 3d 478,
State v. Palmer
148 Ohio App. 3d 246,
, ¶4 -- "When a co-defendant has pleaded guilty, but has not yet been sentenced, he may properly assert his Fifth Amendment privilege, as the plea-bargaining process has not yet been completed."
State v. Walker
, 161 Ohio App. 3d 745,
-- In implementing a negotiated plea the court nolled one too many charges. The judge believed that having done so he could not "reactivate the indictment." Without legal analysis this is said to be a correctable mistake.
State v. Simms
(1983), 9 Ohio App. 3d 302 -- The purpose of cross-examination concerning witness' plea bargain is not to demonstrate that it was illegal. The important consideration is to show motive to fabricate in order to have the benefit of the plea bargain.
State v. Frazier
(1995), 73 Ohio St. 3d 323 -- Syllabus: "In determining admissibility of statements made during alleged plea discussions, the trial court must first determine whether, at the time of the statements, the accused had a subjective expectation that a plea was being negotiated. The trial court must then determine whether such an expectation was reasonable under the circumstances. (Evid. R. 410, analyzed."
Bordenkircher v. Hayes
(1978), 434 U.S. 357 -- Prosecutor's open presentation of choice between accepting plea bargain offered or be reindicted as a recidivist found not to be a violation of the Due Process Clause of the Fourteenth Amendment. Also see
State v. Collier
(1984), 22 Ohio App. 3d 25, 29;
Williams v. Missouri
(8th Cir. 1981), 640 F. 2d 140, 142-143;
State v. Collier
(1984), 22 Ohio App. 3d 25.
Blackledge v. Perry
(1974), 417 U.S. 21 -- Due Process violation found where prosecutor indicted defendant on felony assault charge after defendant had taken advantage of state procedure which allowed appeal, in the form of a trial
in the Superior Court, from a misdemeanor conviction arising from the same conduct.
State v. Ball
(1990), 66 Ohio App. 3d 224 -- State may not negotiate out the mandatory fine in certain drug cases. (But would seem accommodation could be reached through finding of indigency, if applicable, or plea to a different offense.)
Harman v. Mohn
(4th Cir. 1982), 683 F. 2d 834, 838 -- "Plea bargains, which include adverse or lenient treatment for some person other than the accused, are not per se invalid, but these situations demand that prosecutors exercise a high degree of good faith in negotiating such pleas and that courts accepting such pleas examine them carefully to insure that the accused understands the plea agreement and the consequences not only to himself, but to such third persons as may be affected by the plea bargain."
David L. Strait
Copyright © Franklin County Public Defender and David L. Strait, 2015
Contents may not be duplicated without express permission.