State v. Campbell, 2014 Ohio 4780

London T. Campbell pleaded guilty in Case A (CR-2013-04-0973) to improper handling of a firearm and child endangering and received two years of community control; a carrying concealed weapon charge was dismissed.
While on community control, Campbell was indicted in Case B (CR-2013-12-3326(B)) on two counts of robbery, theft from the elderly, and misuse of a credit card; this indictment triggered a community-control violation in Case A.
Under a plea agreement in Case B Campbell agreed to plead guilty to all four counts and to testify against a co-defendant; the State agreed to recommend a three-year prison term and requested a PSI and victim impact statements.
The written plea form signed by Campbell listed PSI, restitution, and "no contact w/ vic" and explicitly stated the prosecutor’s recommendation need not be followed by the court.
The trial court conducted a Crim.R. 11 colloquy, accepted the pleas, ordered a PSI/VIS, and later sentenced Campbell to 4.5 years in Case B and 12 months in Case A, to run concurrently (total 4.5 years); it also imposed a no-contact order.
Campbell appealed, raising (1) that the court violated the plea agreement by exceeding the three-year recommendation, (2) ineffective assistance for failing to object to that excess sentence, (3) that the no-contact order was unlawful, and (4) ineffective assistance for failure to challenge the no-contact order.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Campbell)	Held
Whether the trial court violated the plea agreement by imposing a sentence greater than the State’s 3-year recommendation	The court may sentence as it deems appropriate; plea agreement was advisory as to sentencing	The court breached the plea agreement and should have sentenced to the recommended 3 years or allowed withdrawal	Held for State: court not bound by prosecutor’s recommendation; Crim.R. 11 colloquy and written plea notified Campbell the recommendation was not binding, so plea remained voluntary
Whether trial counsel was ineffective for not objecting to the sentence exceeding 3 years	No prejudice because court acted within its sentencing discretion	Counsel was deficient for failing to object to breach of plea agreement	Held for State: no prejudice because sentence was lawful; ineffective-assistance claim fails
Whether the no-contact order was unlawful after incarceration began	Court may impose no-contact as part of sentence; plea included no-contact term	No-contact order exceeded court’s authority once prison term imposed	Held for State: no-contact order valid here (consistent with plea); court’s prior precedent supports imposition
Whether trial counsel was ineffective for not objecting to the no-contact order	No prejudice because order lawful and part of plea	Counsel should have challenged unlawful no-contact order	Held for State: no prejudice because order lawful; ineffective-assistance claim fails

State v. Campbell, 90 Ohio St.3d 320 (2000) (doctrine of invited error and enforcing plea terms)
Hal Artz Lincoln-Mercury, Inc. v. Ford Motor Co., 28 Ohio St.3d 20 (1986) (invited error principle cited regarding party-induced rulings)