State v. Easterly
2013 Ohio 2961
Ohio Ct. App.2013Background
- Easterly appeals a trial court decision discharging him from post-release control and denying plea withdrawal.
- In 2002 Easterly pled guilty to involuntary manslaughter and three felonious assaults with concurrent terms totaling nine years, plus firearm specifications.
- Plea and sentencing documents described mandatory post-release control (five years for first-degree, three years for second-degree) and notice procedures.
- The sentencing hearing and the entry failed to reiterate post-release control details, though notices under R.C. 2929.19(B)(3) were acknowledged.
- In 2006 Easterly received judicial release with five years of community control, which he later violated; the court reimposed the nine-year term with continued monitoring.
- In 2011 Easterly moved to vacate his guilty plea, arguing the sentence was void for improper post-release control imposition; the court discharged him from post-release control and denied plea withdrawal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether void post-release control renders the entire sentence void | Easterly argues improper PRC imposition voids the sentence and plea. | State contends only the PRC portion is void; conviction remains valid. | Only the PRC portion is void; conviction remains valid. |
| Whether the withdrawal motion is a presentence or post-sentence motion | Boswell-type presentence standard should apply for freely granting withdrawal. | Fischer moratorium precludes treating as pure presentence; post-sentence analysis applies. | Motion treated as post-sentence; no manifest injustice shown. |
| Whether the post-release control defect warrants granting withdrawal request | Void sentence plus post-release control defect equates to manifest injustice. | Lack of manifest injustice; there was no basis to withdraw plea. | Not an extraordinary case; no manifest injustice; denial affirmed. |
Key Cases Cited
- State v. Fischer, 128 Ohio St.3d 92 (2010) (only PRC portion void; not entire sentence)
- State v. Boswell, 121 Ohio St.3d 575 (2009) (presentence withdrawal liberal standard; resentencing when remanded)
- State v. Singleton, 124 Ohio St.3d 173 (2009) (PRC procedure prospective for post-2006 sentences)
- State v. Pullen, 2012-Ohio-1498 (2012) (prospective application of PRC procedures)
- State v. Triplett, 2012-Ohio-4529 (2012) (partial void sentence; conviction not voided)