State v. Bloodworth, 2019 Ohio 1222

Gregory A. Bloodworth pleaded guilty to one count of burglary (R.C. 2911.12(A)(2)).
Written plea agreement listed the maximum penalty, stated no promises were made, and noted a presentence investigation; it also said the State was free to argue sentence.
At the plea colloquy the court confirmed the plea terms, advised that sentence could be consecutive, and Bloodworth affirmed no promises were made.
After a presentence investigation the court sentenced Bloodworth to seven years, consecutive to another sentence; he expressed dissatisfaction afterward.
One week later Bloodworth filed a pro se post-sentence Crim.R. 32.1 motion to withdraw his plea, claiming he relied on counsel’s alleged promise of a five-year-or-less sentence; the trial court denied the motion without a hearing.
Bloodworth appealed both the conviction and the denial of his motion; the Ninth District Court of Appeals affirmed.

Issue	Plaintiff's Argument (Bloodworth)	Defendant's Argument (State / Trial Court)	Held
Whether counsel was ineffective in advising plea (inducing plea by promising ≤5-year sentence)	Counsel told Bloodworth he would receive five years or less; but for that promise he would not have pled guilty	Plea agreement and on-the-record colloquy show no promises; alleged off-record assurances are not reflected in the record	Overruled. Claim depends on facts outside the record and thus cannot be resolved on direct appeal; ineffective-assistance claim not reviewable here
Whether trial court abused discretion by denying post-sentence Crim.R. 32.1 motion without a hearing	Bloodworth argued his plea was involuntary due to counsel’s promise, so a hearing was required	Court denied hearing; post-sentence withdrawal motions are discretionary and a hearing is not always required; appellant failed to develop argument showing abuse of discretion	Overruled. No abuse of discretion shown; hearing not required under these circumstances

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective assistance test)
Hill v. Lockhart, 474 U.S. 52 (applies Strickland to guilty-plea challenges)
State v. Ketterer, 111 Ohio St.3d 70 (prejudice standard for plea-related ineffective assistance)
State v. Cooperrider, 4 Ohio St.3d 226 (ineffectiveness claims relying on facts outside the record cannot be resolved on direct appeal)
State v. Madrigal, 87 Ohio St.3d 378 (post-conviction review where record lacks facts necessary to decide ineffectiveness claim)
State v. Barnett, 73 Ohio App.3d 244 (guilty plea waives ineffective-assistance claims unless plea was involuntary)
State v. Smith, 49 Ohio St.2d 261 (standard of review for Crim.R. 32.1 plea-withdrawal motions)