State v. Freeman, 2014 Ohio 5725

Freeman pleaded guilty to one count of engaging in a pattern of corrupt activity and four counts of aggravated robbery, with firearm specifications on two counts, under Crim.R.11; additional firearm spec on count five dismissed.
Indictment (Jan 10, 2013) charged Freeman with nine counts related to multiple robberies: Family Dollar in Boardman (Sept. 22, 2012), Family Dollar in Youngstown (Oct. 2, 2012), Subway (Oct. 19, 2012), and another Boardman Family Dollar (Nov. 10, 2012).
Freeman, age 20 at the time, recruited juveniles to help commit the robberies, along with co-defendants.
Sentencing (Feb. 5, 2014) produced an aggregate 11-year term: concurrent five-year terms for counts 1–5, plus three-year firearm specs to be served before/consecutively to the underlying felonies.
Appointed counsel filed a no-merit brief under State v. Toney; Freeman did not file a pro se brief.
Appellate court independently reviewed for merit and concluded the assignments of error lacked merit; affirmed the conviction and sentence and permitted counsel to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of counsel	Freeman	Freeman	Without merit
voluntariness of the Crim.R.11 plea	Freeman	Freeman	Plea valid; entered knowingly, intelligently, voluntarily

State v. Toney, 23 Ohio App.2d 203 (Seventh Dist. 1970) (indigent defendant's right to court-appointed counsel on direct appeal)
State v. Veney, 120 Ohio St.3d 176 (2008) (substantial compliance test for Crim.R.11 nonconstitutional advisements)
State v. Nero, 56 Ohio St.3d 106 (1990) (substantial compliance standard for Crim.R.11)
State v. Wilkins, 64 Ohio St.2d 382 (1980) (reasonableness of counsel's decisions evaluated at decision time)
State v. Bonnell, 140 Ohio St.3d 209 (2014) (consecutive-sentence findings required at sentencing and in judgment)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)