State v. Chatman
2017 Ohio 8101
| Ohio Ct. App. | 2017Background
- Maurice Chatman was indicted for Domestic Violence (with two prior offenses, a third-degree felony) and Violation of a Protection Order (with a prior, fifth-degree felony).
- On March 17, 2017, Chatman pleaded guilty to Domestic Violence; the State dismissed the protection-order count in exchange for a sentencing cap agreement.
- The parties agreed that, if the court imposed prison, the term could not exceed 24 months; the agreement removed exposure to 30- or 36-month terms.
- A pre-sentence investigation (PSI) was ordered; after the court received the PSI, Chatman was sentenced on April 6, 2017 to 24 months' imprisonment.
- Appellate counsel filed an Anders brief asserting no meritorious issues and identified three potential issues for independent review; Chatman filed no pro se brief.
- The appellate court conducted an independent Anders review and affirmed the trial court, finding no arguable issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective | State argued record shows no Strickland violation; plea/sentencing counsel acted reasonably | Chatman suggested ineffective assistance (as raised by appellate counsel) | No ineffective assistance; no arguable Strickland claim |
| Whether sentencing to maximum allowed by plea agreement was erroneous | State maintained sentence complied with the parties' agreement and was permitted | Chatman challenged imposition of the 24-month maximum | Affirmed: sentencing within agreed 24-month cap was proper |
| Whether trial court complied with Crim.R. 11 in accepting plea | State argued the plea was knowingly, intelligently, and voluntarily entered and Crim.R. 11 was satisfied | Chatman contended plea colloquy may have been deficient | Affirmed: full compliance with Crim.R. 11; plea valid |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (requires counsel to file brief identifying any potential arguable issues and court to conduct independent review when counsel seeks to withdraw)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)