State v. Clark, 2022 Ohio 2693

Juvenile court complaint (Feb 4, 2021) alleged multiple homicides, burglaries, and robberies; Clark waived probable-cause hearing and case was transferred to common pleas.
Clark was indicted (May 6, 2021) and pled not guilty; on July 20, 2021 he entered a plea agreement.
Plea: guilty to amended Count 1 (involuntary manslaughter, R.C. 2903.04(A)) with two specifications, and Count 8 (aggravated robbery, R.C. 2911.01).
Sentenced under the Reagan Tokes Act to consecutive terms: aggregate definite minimum 16 years and indefinite maximum 21 years (includes a mandatory 3-year firearm specification and 3 years for aggravated robbery); counsel did not object to Reagan Tokes at sentencing.
Clark appealed, raising (1) that the Reagan Tokes Act is unconstitutional (separation of powers, jury-trial, due process), and (2) ineffective assistance for counsel’s failure to object; the trial court’s judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of the Reagan Tokes Act (R.C. 2967.271)	The State: the Act is constitutional and may be applied at sentencing.	Clark: the Act violates separation of powers, the right to jury trial, and due process.	Court: Reagan Tokes is constitutional; overrules Clark’s challenge (relies on this district’s recent decisions).
Ineffective assistance for failure to object to Reagan Tokes	The State: counsel’s omission caused no prejudice because the Act is constitutional.	Clark: counsel was ineffective under Strickland for not objecting to the Act.	Court: No prejudice shown; claim fails because the Act is constitutional.

Strickland v. Washington, 466 U.S. 668 (establishes the two‑prong ineffective-assistance standard)
State v. Bradley, 42 Ohio St.3d 136 (Ohio adopts Strickland framework for ineffective-assistance claims)