State v. Corchardo, 2017 Ohio 4390

Defendant Brendalize Corchado was convicted after a bench trial of one count of misdemeanor assault arising from a road‑rage incident in which she and her boyfriend boxed in the victim's car; Corchado admitted exchanging blows and left her four‑month‑old child in her vehicle during the incident.
Victim testimony described Corchado striking the passenger through an open window and the boyfriend allegedly retrieving a machete (not recovered); victim later found Corchado's car keys in the victim's car.
Corchado testified and denied being the primary aggressor, blaming the victims for initiating the confrontation.
The trial court found Corchado guilty, ordered a presentence investigation (PSI), and later sentenced her to 90 days in jail (the PSI recommendation), mental health evaluation, anger management, two years of intensive probation, fines/costs, and no contact with the victim; maximum exposure was 180 days.
Corchado appealed, arguing (1) the trial judge's hostile comments at trial and sentencing demonstrated bias and violated due process, and (2) trial counsel was ineffective for failing to move to disqualify the judge after the verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial‑judge bias at trial/sentencing (due process)	State argued judge's critical comments were based on record facts and did not amount to unconstitutional bias.	Corchado argued the judge's intemperate, shaming remarks showed prejudice and deprived her of due process.	Court held comments were ill‑advised but did not rise to a due‑process violation; sentence (90 days) was not an abuse of discretion.
Ineffective assistance for not moving to disqualify judge	State argued such a motion would have been meritless because judicial comments during sentencing ordinarily do not warrant disqualification.	Corchado argued counsel was deficient for failing to file an affidavit/motion to disqualify after verdict and before sentencing.	Court held counsel was not ineffective: a disqualification motion would have failed and Corchado suffered no prejudice (sentence followed PSI recommendation and was well under the statutory maximum).

Arnett v. State, 88 Ohio St.3d 208, 724 N.E.2d 793 (Ohio 2000) (judicial comments involving protected status can raise due process concerns)
Liteky v. United States, 510 U.S. 540 (U.S. 1994) (opinions formed from the record are not a basis for disqualification absent deep‑seated antagonism)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong test for ineffective assistance of counsel)
State v. Bradley, 42 Ohio St.3d 136, 538 N.E.2d 373 (Ohio 1989) (adopting Strickland standard in Ohio)
State v. Dean, 127 Ohio St.3d 140, 937 N.E.2d 97 (Ohio 2010) (criticisms of defendant based on record do not alone show bias making fair judgment impossible)
State v. Kelly, 179 Ohio App.3d 666, 903 N.E.2d 365 (Ohio Ct. App. 2008) (counsel not ineffective for failing to file meritless motions)
State v. Hamblin, 37 Ohio St.3d 153, 524 N.E.2d 476 (Ohio 1988) (licensed attorney presumed competent)