State v. Baker, 2014 Ohio 1967

Baker was convicted by guilty plea on multiple charges related to a home invasion, robbery, and assault of an elderly victim, resulting in a 20-year aggregate term.
The State offered plea deals; Baker initially rejected a 15-year offer and later accepted an 18-year offer that was retracted before final negotiations.
Codefendant Colin Stout accepted a 15-year plea without judicial release, while Baker’s offers fluctuated between 15 and 18 years.
Baker sought to withdraw his appointed counsel claiming a breakdown in the attorney-client relationship amid contested plea negotiations, but the trial court denied withdrawal.
Baker ultimately pled guilty with new counsel, and at sentencing the court imposed a 20-year term after considering victim impact and other evidence, including prior statements.
The trial court later imposed consecutive sentences without explicit statutory findings under R.C. 2929.14(C)(4), prompting this appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Withdrawal of counsel standard	Baker (appellant) argues a breakdown in the attorney-client relationship justified withdrawal.	State contends no substantial breakdown; withdrawal not warranted.	No abuse; no breakdown of magnitude jeopardizing counsel or right to effective assistance.
Disproportionate sentence to codefendant	Baker asserts longer sentence than Stout despite similar conduct.	State argues discretion allowed; Stout’s and Baker’s culpability differ; no violation of 2929.11(B).	Not clearly and convincingly contrary to 2929.11(B); no error.
Ineffective assistance during sentencing	Counsel failed to argue for parity with Stout at sentencing.	Failure to object did not prejudice the outcome; justification exists for 20 years.	No ineffective-assistance of counsel.
Consecutive-sentencing findings	Consecutive sentences imposed without required findings.	Court weighed factors but did not explicitly state all required findings.	Consecutive-sentencing portion reversed and remanded for proper findings.

State v. Williams, 99 Ohio St.3d 493 (Ohio Sup. Ct. 2003) (abuse-of-discretion standard for withdrawal of counsel)
State v. Coleman, 37 Ohio St.3d 286 (Ohio Sup. Ct. 1988) (breakdown in attorney-client relationship required for new counsel)
Lafler v. Cooper, 132 S. Ct. 1376 (U.S. Supreme Court 2012) (ineffective assistance during plea negotiations; distinguishable fact pattern)
State v. Carter, 2010-Ohio-6316 (Ohio App. 4th Dist. 2010) (good-cause standard for substitution of counsel; voir dire of conflict)
State v. Blankenship, 102 Ohio App.3d 534 (Ohio App. 12th Dist. 1995) (grounds for new counsel include irreconcilable conflict)
State v. Kingery, 2004-Ohio-4605 (Ohio Dist. 5th App. 2004) (presumption of correctness when record lacks certain sentencing materials)