State v. Blashaw, 2012 Ohio 6011

Appellant Blashaw crashed on I-90 May 17, 2009 with two injured daughters; police found him intoxicated and driving with a suspended license.
Indictment on June 9, 2009 charged multiple counts of aggravated vehicular assault and child endanglement, plus DUI and obstructing official business.
On August 6, 2009 Blashaw pled guilty to all counts after being advised of rights and penalties.
On August 27, 2009 the court merged some counts and imposed a 20-year sentence (consecutive 8-year and concurrent counts) with three years mandatory postrelease control.
Blashaw appealed the sentencing in Blashaw I, which this court affirmed; later he moved to withdraw his guilty plea under Crim.R. 32.1 after sentencing.
The trial court denied the Crim.R. 32.1 motion in June 2012; Blashaw timely appealed to this court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post-sentence Crim.R. 32.1 motion shows manifest injustice.	Blashaw argues irregularities in plea colloquy rendered plea void.	Blashaw contends plea was not knowingly or voluntarily made due to improper advisement.	No manifest injustice; presumption of regularity; res judicata bars.
Whether lack of a plea-colloquy transcript invalidates review of the 32.1 motion.	Blashaw claims transcript required to prove irregularities.	No transcript provided; appellant relies on bald claims.	Presumption of regularity due to absence of transcript; affirmance based on Smith I.

State v. Smith, 2010-Ohio-3512 (8th Dist. No. 94063, 2010) (manifest injustice standard for Crim.R. 32.1 post-sentence motion)
State v. Craddock, 2006-Ohio-5912 (8th Dist. No. 87582, 2006) (appellate judgment controls scope of review; res judicata applies)
State v. Perry, Ohio St.2d 175 (1967) (establishes res judicata doctrine in post-conviction context)
State v. Smith, 8th Dist. No. 94063, 2010-Ohio-3512 (8th Dist. 2010) (reaffirmation of manifest injustice and need for transcript)