State v. Dotson
2017 Ohio 918
Ohio Ct. App.2017Background
- On June 13, 2015, Hamilton County deputies stopped Anthony Dotson in a shopping-center parking lot; a search of his person and car yielded a knife, straw, drugs, and paraphernalia.
- Dotson was indicted on five drug-related offenses and moved to suppress evidence from the search; the trial court denied the motion.
- Dotson twice attempted to enter a no-contest plea (once by filing the plea); the trial court expressly refused, stating it has a blanket policy of not accepting no-contest pleas.
- After the court rejected the no-contest plea, Dotson pled not guilty and proceeded to a bench trial.
- The trial court found Dotson guilty, sentenced him to three years of community control and related conditions, and imposed costs.
- On appeal Dotson argued (1) the suppression ruling was erroneous and (2) the court erred in refusing to accept his no-contest plea; the appellate court found the plea issue dispositive.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Dotson) | Held |
|---|---|---|---|
| Whether the trial court properly rejected Dotson's proffered no-contest plea | Trial court may reject plea; Dotson forfeited review by not objecting | Court improperly applied a blanket policy refusing all no-contest pleas and thus failed to consider case-specific facts | Reversed: court abused discretion by refusing plea based on blanket policy; remanded for consideration of no-contest plea |
Key Cases Cited
- State v. Beasley, 49 N.E.3d 378 (Ohio App. 2016) (rejecting blanket refusal to accept no-contest pleas is an abuse of discretion)
- State v. Jenkins, 473 N.E.2d 264 (Ohio 1984) (trial court has broad discretion to accept or reject no-contest pleas)
- Pembaur v. Leis, 437 N.E.2d 1199 (Ohio 1982) (definition of abuse of discretion)
- State v. Carter, 706 N.E.2d 409 (Ohio App. 1998) (blanket policies affecting all defendants improperly bypass case-specific consideration)