State v. Blessing, 2013 Ohio 392

Blessing pled guilty to obstructing justice (fifth-degree) and complicity to having weapons while under disability (third-degree) as part of a plea agreement.
She had previously been charged with two counts of obstructing justice and one count of complicity to having weapons under disability; one obstructing count was dismissed as part of the plea.
The gun was obtained for Ferryman by Blessing’s father; Blessing allegedly aided Ferryman in possessing and using the shotgun despite Ferryman’s mental illness and hospitalization history.
Blessing lied to investigators about the gun’s purchaser in an attempt to conceal her father’s involvement.
The trial court sentenced Blessing to concurrent maximum terms: five years for complicity and one year for obstructing justice.
Blessing timely appealed raising five assignments of error challenging the validity of her plea and various sentencing and procedural decisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Guilty plea knowingly entered	Blessing contends the plea was not knowingly voluntary due to continuance denial and counsel ineffectiveness.	Blessing argues the denial of a continuance coerced her into pleading.	Plea entered knowingly and voluntarily; no reversible error found in continuance denial or counsel ineffectiveness.
Sentence within statutory range / abuse of discretion	State claims sentences within range; court did not abuse discretion.	Blessing asserts maximum sentences and failure to consider 2929.12 factors show abuse of discretion.	Sentences within range; no clear abuse of discretion; 2929.12 factors were considered implicitly.
Post-release control notification at sentencing	Trial court properly notified at plea; sentencing notice lacking.	Court failed to inform about post-release control at sentencing.	Error to notify at sentencing; remand for proper PRC imposition.
Disapproval of shock incarceration / IPP	Court disapproved these programs without stated reasons.	NC argument that court could disapprove without express reasoning.	Remand to provide explicit reasons for disapproval of shock incarceration and IPP.
Costs notification and community service for costs	Court must notify about costs and potential community service for nonpayment.	Costs were mentioned but community service notification was deficient.	Assignment sustained in part; remand for proper costs notification and community-service warning.

State v. Johnson, 40 Ohio St.3d 130 (1988) (plea must be knowing, intelligent, voluntary under Crim.R. 11)
State v. Foster, 109 Ohio St.3d 1 (2006) (mandatory sentencing reforms; no need for judicial findings for max/min)
State v. Kalish, 120 Ohio St.3d 23 (2008) (review of sentencing compliance; statutory framework for sentences)