State v. Campbell, 2021 Ohio 2053

Campbell was indicted for three controlled buys of heroin (one fourth-degree, two third-degree felonies, with school-zone specs) and later consolidated with additional drug indictments.
On the scheduled trial date, Campbell entered a written guilty plea to two counts (one fourth-degree, one third-degree) pursuant to a plea agreement: 18 months and 36 months consecutively (total 54 months), no judicial release, and forfeiture of $997; remaining counts and specs were dismissed.
At the plea hearing the court advised Campbell of constitutional rights, penalties, and post-release control; the court found the plea knowing, intelligent, and voluntary.
A dispute arose at sentencing when Campbell asked for a short delay to get affairs in order; the State sought to withdraw the plea claiming an unwritten agreement not to request release or delayed reporting. The court denied the State’s request, accepted the plea, and imposed the agreed sentence (making consecutive-sentence findings).
Appellate counsel filed an Anders brief arguing no non-frivolous issues, suggesting potential claims: involuntary/unknowing plea, unlawful consecutive sentence, and ineffective assistance of counsel based on off-the-record communications. No pro se brief was filed.
The appellate court conducted an independent Anders review and affirmed, finding no non-frivolous appellate issues and permitting counsel to withdraw.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Campbell)	Held
1. Was Campbell’s plea knowing, intelligent, and voluntary?	Court complied with Crim.R. 11; plea was valid.	Plea possibly defective due to disparity between oral statements about an unwritten no-release condition and the written agreement.	Court: Plea valid; advisements sufficient; Campbell understood written agreement; claim frivolous.
2. Was the jointly recommended consecutive sentence contrary to law?	Sentence was jointly recommended, within statutory ranges, and authorized by law.	Consecutive imposition challenged as improper.	Court: No review under R.C. 2953.08(D)(1); sentence authorized and jointly recommended; consecutive findings made and lawful.
3. Did trial counsel render ineffective assistance concerning the plea negotiations?	Trial counsel was adequate; alleged communications outside the record cannot support ineffective-assistance claim on direct appeal.	Campbell alleges counsel pressured him into the plea, made unconsented deals, and suggested firing counsel.	Court: Claim relies on out-of-record matters; not cognizable on direct appeal and frivolous here.
4. Was denial of Campbell’s motion for release on bond pending appeal erroneous?	Denial appropriate and even if erroneous, no relief available to appellant making the claim moot.	Campbell sought release pending appeal after sentencing.	Court: Considered and found any error would be moot; no reversible issue.

Anders v. California, 386 U.S. 738 (1967) (procedures for withdrawal of appointed counsel when counsel finds appeal frivolous)
Penson v. Ohio, 488 U.S. 75 (1988) (appellate court must independently review record when counsel files Anders brief)
Boykin v. Alabama, 395 U.S. 238 (1969) (constitutional requirement that guilty plea be knowing, voluntary, and intelligent)
State v. Clark, 893 N.E.2d 462 (Ohio 2008) (Crim.R. 11 and plea-advisement requirements)
State v. Bishop, 124 N.E.3d 766 (Ohio 2018) (distinguishing constitutional and nonconstitutional advisements under Crim.R. 11)
State v. Dangler, 164 N.E.3d 286 (Ohio 2020) (prejudice requirement when nonconstitutional advisement is not fully given)
State v. Underwood, 922 N.E.2d 923 (Ohio 2010) (statutory bar on appellate review when sentence is jointly recommended and authorized)
State v. Sergent, 69 N.E.3d 627 (Ohio 2016) (consecutive-sentence findings not required when sentence is jointly recommended, but permissible to make them)