State v. Chisenhall, 2016 Ohio 999

After a high-speed chase while intoxicated (BAC .17) and driving on a suspended license, Paul Chisenhall crashed, killing two passengers and seriously injuring a third.
Chisenhall pled guilty pursuant to a plea agreement to two counts of aggravated vehicular homicide (with specifications) and one count of aggravated vehicular assault; ten other charges were dismissed.
More than two months after pleading guilty, on the day of sentencing Chisenhall orally moved to withdraw his guilty plea, claiming shock about the sentence, lack of discovery review, and desire for the families to hear more facts.
The trial court held a hearing on the presentence motion, denied withdrawal, and imposed consecutive sentences totaling 25 years (including mandatory and specification terms).
On appeal, Chisenhall challenged (1) the denial of his motion to withdraw the plea and (2) alleged sentencing defects, including failure to incorporate consecutive-sentence findings into the journal and several statutory notifications.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying a presentence motion to withdraw the guilty plea	The State argued the plea was knowingly, voluntarily entered, discovery did not undermine guilt, and factors weigh against withdrawal	Chisenhall argued he was shocked by the true sentencing range, had not reviewed discovery, and wanted facts aired for victims and the court	Denial affirmed: trial court did not abuse discretion after weighing Xie factors; delay, full Crim.R.11 colloquy, competent counsel, overwhelming evidence, and possible prejudice to the State weighed against withdrawal
Whether the sentence must be vacated/remanded for sentencing defects (consecutive findings and statutory notifications)	The State maintained the court made required consecutive-sentence findings at the hearing and other notification omissions were harmless	Chisenhall argued the journal did not include the required R.C. 2929.14(C)(4) findings, and court failed to give statutory notifications about drug/DNA testing and earned-credit matters	Court affirmed sentence but remanded for limited purpose: issue a nunc pro tunc entry incorporating the consecutive-sentence findings; other notification omissions were harmless error and did not require resentencing

State v. Xie, 62 Ohio St.3d 521 (establishes Xie factors and standard for presentence plea-withdrawal motions)
State v. Bonnell, 140 Ohio St.3d 209 (requires consecutive-sentence findings be stated at sentencing and incorporated into the journal; clerical omission may be corrected by nunc pro tunc entry)