State v. Benson, 2017 Ohio 8150

Robert L. Benson was indicted in three criminal dockets (thefts, receiving stolen property, drug possession/paraphernalia, burglary, driving under suspension, obstructing), pleaded guilty to those charges, and was set for sentencing.
Benson failed to appear at the scheduled sentencing hearing; the court issued a capias (arrest warrant).
After the capias, Benson was indicted in a fourth case (theft) and later pleaded guilty to that count after the court had already sentenced him on the earlier pleas.
At the sentencing hearing for the first three cases Benson orally moved to withdraw his pre‑sentence guilty pleas, asserting he sought withdrawal because the State no longer intended to recommend the originally agreed 2‑year total sentence (the State conditioned that recommendation on his appearance).
The trial court denied the presentence motion to withdraw, sentenced Benson to an aggregate 4 years 3 months, and later accepted a guilty plea in the fourth case and ran that sentence concurrently.
Benson filed delayed appeals in all four dockets; the Ninth District consolidated the appeals and affirmed the trial court’s denial of the motion to withdraw (any challenge to the fourth case plea was rejected because no pre‑sentence motion to withdraw was filed there).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Benson)	Held
Whether the trial court abused its discretion by denying Benson’s presentence motion to withdraw his guilty pleas	The court properly denied withdrawal because Benson’s failure to appear voided the State’s conditional plea recommendation; the court had discretion and could limit the hearing	Benson argued the court failed to give full and fair consideration and that withdrawal would not prejudice the State; he sought withdrawal solely because the State rescinded the 2‑year recommendation	The court affirmed: no abuse of discretion in denying withdrawal where plea was competent, plea hearing adequate, motion limited to avoiding a harsher sentence after failure to appear, and trial court reasonably limited the hearing

State v. Xie, 62 Ohio St.3d 521 (sets standard that pre‑sentence withdrawal should be freely allowed but requires a hearing to determine whether a reasonable and legitimate basis exists)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (defines abuse of discretion as arbitrary, unreasonable, or unconscionable)