State v. Artis, 2020 Ohio 4018

In December 2011 Artis pleaded guilty in two Bellefontaine Municipal Court cases to first‑degree misdemeanor domestic violence and was sentenced to consecutive jail terms (3 days and 14 days). He did not directly appeal those convictions.
In May 2018 a grand jury indicted Artis for domestic violence; the charge was elevated to a third‑degree felony based on his 2011 convictions.
A jury convicted Artis of the 2018 offense and he was sentenced to 36 months; that conviction was affirmed on direct appeal in May 2019.
In October 2019 Artis filed post‑sentence motions in the 2011 cases to withdraw his guilty pleas, arguing the pleas were uncounseled and therefore not knowing, intelligent, and voluntary.
The trial court denied the motions; Artis appealed. The Third District affirmed, holding the claims were barred by res judicata and the trial court did not abuse its discretion in denying the post‑sentence withdrawal motions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in denying Artis's post‑sentence motions to withdraw his 2011 guilty pleas based on an alleged uncounseled plea	The State: Artis could and should have raised the counsel/voluntariness claims on direct appeal; res judicata bars the post‑sentence motion and no manifest injustice is shown	Artis: His 2011 pleas were uncounseled and therefore not knowing, intelligent, and voluntary, violating the Fourteenth Amendment	Affirmed. Court held res judicata bars the claims; trial court did not abuse its discretion in denying the motions

State v. Smith, 49 Ohio St.2d 261 (defines standard for postsentence withdrawal and "manifest injustice")
State v. Adams, 62 Ohio St.2d 151 (abuse of discretion standard explained)
State v. Ketterer, 126 Ohio St.3d 448 (res judicata bars claims that were or could have been raised on direct appeal)
State v. Sarkozy, 117 Ohio St.3d 86 (a defendant may challenge a guilty plea on direct appeal)
State v. Straley, 159 Ohio St.3d 82 (postsentence plea‑withdrawal relief is extraordinary; res judicata principles applied)
State v. Nathan, 99 Ohio App.3d 722 (discussion of appellate standard for reviewing denial of plea‑withdrawal motions)