2018 Ohio 1671
Ohio Ct. App.2018Background
- Defendant Orlando L. Bradley pleaded guilty to obstructing official business (R.C. 2921.31(A)) in Ashtabula County Court of Common Pleas.
- Plea was entered in open court with counsel and a written plea; the trial court accepted the plea.
- Sentence: 90 days in jail suspended, one year community control, and a $750 fine (state’s recommendation).
- Bradley filed a pro se direct appeal arguing his conduct did not support conviction (i.e., sufficiency of the evidence).
- He did not move to withdraw the plea and did not contend the plea was unknowing, involuntary, or in violation of Crim.R. 11.
- Court held a guilty plea is a complete admission of guilt and precludes a direct-appeal challenge to the sufficiency of the evidence; affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bradley can challenge sufficiency of the evidence after pleading guilty | State: Guilty plea waives sufficiency challenge; plea is admission of guilt | Bradley: His conduct did not fall within R.C. 2921.31(A); conviction unsupported by facts | Court: Plea waives right to contest sufficiency; appeal denied |
Key Cases Cited
- State v. Siders, 78 Ohio App.3d 699 (11th Dist. 1992) (guilty plea precludes appeal on merits or sufficiency)
- State v. Wood, 48 Ohio App.2d 339 (Ohio Ct. App. 1976) (guilty plea supplies necessary proof and the trial court need not weigh evidence to accept plea)