State v. Botts, 2019 Ohio 3801

Jeffrey Botts was indicted on three felonies: failure to comply (3rd), aggravated trafficking (1st), and aggravated possession (1st). A plea offer from the State (apparently a six-year resolution) existed before trial.
On the morning of the scheduled jury trial Botts attempted to accept the State’s plea offer; the trial judge stated a courtroom policy that negotiated pleas would not be accepted on the day of trial and that pleas taken that morning must be as charged.
Botts pleaded guilty as charged; the court merged the drug counts, the State elected to proceed on aggravated trafficking and the court imposed 4 years on trafficking plus 2 years on failure to comply, to be served consecutively, for an aggregate 6-year prison term; a 30-year driver’s license suspension was imposed.
Botts appealed, arguing the trial court abused its discretion by rejecting the negotiated plea on the day of trial based on a blanket policy.
The Second District affirmed, concluding the court followed a general (not absolute) pretrial plea-cutoff policy reflected in its pretrial order, Botts had earlier rejected the offer, and no extenuating circumstances justified deviation.
Judge Donovan dissented, arguing the trial court applied an unyielding blanket rule and failed to consider Botts’s claim he had attempted to notify counsel earlier; he would have reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by refusing to accept a negotiated plea on the morning of trial	The court’s general pretrial plea-cutoff policy was reasonable; Botts had rejected the offer earlier and had opportunity to accept it before trial day	Botts argued the court applied a blanket rule and failed to consider his assertion that he tried to accept the plea before trial morning (miscommunication with counsel)	No abuse of discretion; court’s general policy (set in pretrial order) justified refusing the negotiated plea absent extenuating circumstances

City of Akron v. Ragsdale, 61 Ohio App.2d 107 (9th Dist. 1978) (trial court discretion to reject plea but must not be exercised as an absolute policy)
State v. Jenkins, 15 Ohio St.3d 164 (Ohio 1984) (discussing trial-court discretion over plea acceptance)
State v. Carter, 124 Ohio App.3d 423 (2d Dist. 1997) (trial court may not replace case‑specific discretion with a blanket policy when rejecting pleas)
State v. Fitzgerald, 188 Ohio App.3d 701 (8th Dist. 2010) (blanket rejection of pleas after trial date set can be an abuse of discretion)