State v. Coppock
2017 Ohio 2881
| Ohio Ct. App. | 2017Background
- Defendant Lora K. Coppock was arrested after a traffic stop and charged with possession of MDMA (aggravated possession) and 0.3 g crack cocaine; she later agreed to plead guilty to aggravated possession of MDMA in exchange for dismissal of the cocaine charge.
- She waived indictment and preliminary hearing in municipal court and the case was bound over to the Miami County Common Pleas Court.
- At the June 27, 2016 plea hearing Coppock pleaded guilty to aggravated possession (a felony) and acknowledged the plea colloquy; she was later sentenced to nine months’ imprisonment on August 30, 2016.
- At the plea colloquy Coppock stated she had two mental illnesses and a terminal physical illness and at times questioned aspects of the charges (e.g., whether cocaine was involved), but also repeatedly answered the court’s questions affirmatively, confirmed literacy and age, and confirmed she was not under the influence of drugs or alcohol.
- Defense counsel told the court he believed Coppock understood the proceedings and the nature of the plea based on his prior interactions with her.
- Coppock appealed, arguing (1) her plea was not knowing, intelligent, and voluntary because her illnesses impaired understanding; and (2) the court improperly relied on defense counsel’s statements about her understanding rather than ensuring her own comprehension.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Coppock) | Held |
|---|---|---|---|
| Whether the trial court complied with Crim.R. 11 and accepted a knowing, intelligent, and voluntary guilty plea | Court complied with Crim.R. 11; record shows Coppock was advised of charges, penalties, and constitutional rights and affirmed understanding | Coppock asserted mental and physical illnesses prevented true understanding so plea was not knowing/voluntary | Affirmed: Plea valid. Court conducted required Crim.R. 11 advisements and Coppock’s responses and conduct showed sufficient understanding |
| Whether the court erred by relying on defense counsel’s statements about the defendant’s understanding | The court may consider counsel’s statements as supplemental evidence but must obtain the defendant’s own responses; here defendant personally answered questions | Coppock contends the court improperly relied on counsel instead of ensuring the forms and waiver were explained to her | Affirmed: No error. Court obtained Coppock’s own responsive statements; counsel’s remarks were permissible corroboration |
Key Cases Cited
- Veney, 897 N.E.2d 621 (Ohio 2008) (Crim.R. 11 governs felony pleas and specifies required advisements)
- Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (a guilty plea must be knowing, intelligent, and voluntary)
- Ballard, 423 N.E.2d 115 (Ohio 1981) (trial court may not substitute counsel’s statements for the defendant’s own answers but may consider counsel’s comments as corroboration)