State v. Eckley, 2017 Ohio 8455

In Oct 2012 Shannon Eckley was charged with two counts of child endangering and pleaded guilty in Dec 2012; she was sentenced to community control in Feb 2013.
Between plea and sentencing defense counsel learned of additional facts suggesting Eckley had been coerced and abused by roommates Jessica Hunt and Jordie Callahan; counsel noted the possibility Eckley was a victim held under duress.
Federal prosecutions of Hunt and Callahan later produced a Sixth Circuit opinion (United States v. Callahan) detailing prolonged physical and psychological abuse and forced labor of Eckley and her child.
In Nov 2016 Eckley moved to withdraw her guilty plea (or alternatively to seal the record), arguing the newly revealed evidence supported a duress defense and that her plea was the result of manifest injustice.
The trial court denied the post-sentence motion without an evidentiary hearing, finding the duress circumstances were known at the time of plea and the plea was voluntary, intelligent, and knowing.
The Fifth District Court of Appeals reversed and remanded, holding the trial court abused its discretion by denying a hearing because material facts outside the record could show manifest injustice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by refusing an evidentiary hearing on Eckley’s post‑sentence motion to withdraw her plea	The State argued the duress-related facts were known at plea/sentencing and the plea was voluntary and valid	Eckley argued material, newly revealed facts (from federal convictions) and her developmental disability meant the plea may have been induced by duress and an evidentiary hearing was required	The court held the trial court abused its discretion by denying a hearing because the motion alleged facts outside the record that, if true, could show manifest injustice; remanded for further proceedings
Whether denial of the motion constituted manifest injustice	The State maintained federal convictions did not undermine the voluntariness of Eckley’s plea	Eckley maintained the later-disclosed, detailed abuse evidence could show she pleaded guilty under duress and without appreciation of waived defenses	Decision on manifest injustice was premature; the appellate court required an evidentiary hearing first

Smith v. State, 49 Ohio St.2d 261 (Ohio 1977) (standard for postsentence plea withdrawal limited to manifest injustice)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (definition of abuse of discretion)
State v. Francis, 104 Ohio St.3d 490 (Ohio 2004) (timeliness of withdrawal motions is a contextual factor)
United States v. Callahan, 801 F.3d 606 (6th Cir. 2015) (factual findings describing prolonged coercive abuse and forced labor relevant to duress defense)