State v. Coyle, 2016 Ohio 7686

A confidential informant implicated Jeremy Coyle in multiple drug sales in Greene County; police conducted four controlled buys and surveillance.
Investigation linked Coyle to 1127 Beaumont Avenue, Dayton (Montgomery County) via utility records for his girlfriend Megan White, vehicle sightings, and a trash pull behind the house that yielded drug-related items and a bill addressed to Coyle at that address.
A search warrant for the Dayton residence uncovered multiple illicit drugs and a clandestine laboratory; Coyle was indicted on 29 drug-related counts (possession, trafficking, manufacture).
Coyle filed a motion to suppress the evidence discovered at the residence but entered a plea agreement before the motion was decided, pleading guilty to 11 counts and stipulating to a 12-year prison sentence.
Coyle appealed, arguing (1) improper venue in Greene County and (2) ineffective assistance of counsel for advising him to plead guilty (including not waiting on suppression ruling, not challenging venue, and advising acceptance of the plea).
The appellate court affirmed, rejecting both assignments of error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Venue proper in Greene County	State: court had jurisdiction; venue challenge waived by guilty plea	Coyle: venue was improper in Greene County and should have been contested	Guilty plea waived venue claim; assignment overruled
Ineffective assistance of counsel	State: counsel’s advice was reasonable given strength of evidence and probable-cause support for warrant; Coyle’s plea was voluntary	Coyle: counsel was ineffective for advising plea before suppression ruling, failing to challenge venue, and urging acceptance of 12-year stipulated sentence	Strickland/Hill standard applies; court found counsel’s performance reasonable and no prejudice—assignment overruled

Strickland v. Washington, 466 U.S. 668 (1984) (two-part standard for ineffective assistance of counsel)
Hill v. Lockhart, 474 U.S. 52 (1985) (Strickland applied to guilty-plea challenges; defendant must show plea was not knowing and voluntary)
Tollett v. Henderson, 411 U.S. 258 (1973) (guilty plea waives pre-plea non-jurisdictional claims except those affecting plea voluntariness)
McMann v. Richardson, 397 U.S. 759 (1970) (counsel’s advice must be within the range of competence demanded of criminal attorneys)
State v. Davis, 851 N.E.2d 515 (Ohio Ct. App. 2006) (discussing affidavit reliability and good-faith exception in suppression contexts)
State v. Longo, 446 N.E.2d 1145 (Ohio Ct. App. 1982) (counsel’s effective assistance does not guarantee a particular result)