State v. Gardner, 2013 Ohio 2269

Gardner was indicted on one count of having weapons under disability and one count of receiving stolen property (firearm) arising from a March 24, 2012 incident while he was on post-release control from a 2008 domestic violence conviction.
Gardner moved to suppress evidence from the Second Ave residence search and his arrest, challenging standing and the legality of entry.
The trial court held Gardner lacked standing to challenge the search and that police had probable cause to arrest; it also narrowed other-acts evidence at suppression hearing.
Gardner withdrew not-guilty pleas and entered guilty pleas to both counts on July 5, 2012 in exchange for the State’s agreement to drop related burglary and prior domestic violence charges, and the court sentenced him to an aggregate term of three years.
Gardner challenges ineffective assistance of counsel, asserting trial counsel should have advised a no-contest plea would preserve his right to appeal the suppression denial; the issue is raised on appeal.
The appellate court applied Strickland v. Washington (Bradley framework) and rejected Gardner’s ineffective-assistance claim, affirming the conviction and sentence

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel’s performance was ineffective for advising a guilty plea that waived suppression appeal	Gardner	Gardner's trial counsel failed to advise a no-contest plea would preserve suppression appeal rights	Denied; no prejudice shown; guilty plea upheld

Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes two-pronged ineffective-assistance standard)
Bradley, 42 Ohio St.3d 136 (Ohio 1989) (adopts Strickland standard in Ohio)
Sallie, 81 Ohio St.3d 673 (Ohio 1998) (preserves focus on prejudice in ineffective-assistance claims)