State v. Gaddy, 2020 Ohio 430

Gaddy was indicted in 2008 for aggravated burglary and aggravated robbery (first-degree felonies with firearm specifications) arising from a 2007 armed home invasion; a separate 2018 indictment charged failure to appear (fourth-degree felony).
Trial on the 2008 charges began in April 2019; after roughly a day and a half of the State’s case (which included expected DNA and ballistic evidence linking Gaddy to firearms and a bullet removed from him), Gaddy accepted a plea agreement for both cases.
The plea hearing complied with Crim.R. 11; the State conceded offenses merged and the plea reduced exposure. Sentencing was continued for a presentence investigation.
Before sentencing Gaddy filed pro se and later counsel-assisted motions to withdraw his guilty pleas, alleging ineffective assistance (failure to share discovery, poor trial tactics, and failure to obtain hospital records). He also had earlier filed (then orally withdrew) a pro se motion for substitution of counsel.
The trial court held a hearing on the motions, denied both presentence motions to withdraw pleas, and sentenced Gaddy to 10 years (aggravated burglary) plus a mandatory 3-year firearm term, consecutive to an 18-month sentence for failure to appear.
On appeal Gaddy argued (1) the court abused its discretion by denying his motions to withdraw pleas and (2) the court abused its discretion by denying his motion for substitute counsel. The appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying Gaddy’s presentence motions to withdraw guilty pleas	The plea was knowing/voluntary after a full Crim.R. 11 colloquy; the court gave full consideration at a presentence hearing; Gaddy failed to prove counsel was deficient or prejudicial and the State would be prejudiced	Counsel was ineffective (failed to share discovery; poor cross-examination; didn’t obtain hospital records); pleas were entered out of emotion to avoid harsher sentence and Gaddy would have gone to trial but for counsel	Affirmed. No abuse of discretion — plea was knowing/voluntary, hearing was full, and Gaddy failed to show deficient performance or prejudice under Strickland/Xie standard
Whether the trial court abused its discretion by denying Gaddy’s motion for substitute counsel	There was no pending motion because Gaddy expressly withdrew the substitution request on the record at pretrial	Gaddy later renewed complaints about trial counsel and contends the court erred in denying substitute counsel	Affirmed. No error — Gaddy voluntarily withdrew the motion at the March 19, 2019 hearing; no motion remained to be overruled

State v. Xie, 62 Ohio St.3d 521 (Ohio 1992) (establishes standard for evaluating presentence motions to withdraw a guilty plea: court must find a reasonable and legitimate basis).
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel: deficient performance and resulting prejudice).
State v. Adams, 62 Ohio St.2d 151 (Ohio 1980) (definition and standard for abuse of discretion).
State v. Smith, 49 Ohio St.2d 261 (Ohio 1977) (appellate review standard for trial court discretion in criminal matters).