State v. Glaze, 2018 Ohio 2184

In 2015 Glaze was indicted for aggravated murder and two counts of felonious assault with firearm specifications after a shooting that resulted in Sachin Rana’s death.
After plea negotiations, Glaze pled guilty to involuntary manslaughter (with one- and three-year firearm specifications) and two counts of felonious assault (without firearm specs); the parties agreed to a 20–25 year joint sentencing range and that counts would not merge.
The trial court imposed consecutive terms: 11 years (involuntary manslaughter) + 3 years (firearm spec) + 4 years + 4 years (two felonious assaults), for an aggregate 22-year sentence.
Glaze timely appealed, raising three assignments of error: (1) trial court erred by imposing multiple consecutive sentences; (2) trial counsel was ineffective, rendering the plea involuntary; (3) the 22-year sentence was contrary to law (disproportionate/excessive).
The court reviewed ineffective-assistance under Strickland and the plea colloquy/competency stipulation, and concluded counsel’s stipulation to a competency evaluation was reasonable and Glaze was competent when pleading guilty.
The court also held that the agreed 20–25 year sentencing range authorized consecutive terms and therefore, under R.C. 2953.08(D)(1) and controlling Eighth District precedent, the sentence was a jointly recommended, review-barred sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective such that the plea was involuntary	State: counsel’s performance was reasonable; competency evaluation was reliable	Glaze: counsel unreasonably stipulated to competency evaluation, making plea involuntary	Counsel’s stipulation was not objectively unreasonable; Glaze was competent and plea was voluntary — assignment overruled
Whether consecutive sentences imposed within the agreed 20–25 year range are reviewable	State: agreed range authorized the sentence; consecutive terms expected and permitted	Glaze: consecutive sentences were erroneous and sentence contrary to law/excessive	Sentence falls within jointly recommended, authorized range; nonreviewable under R.C. 2953.08(D)(1) — assignments overruled
Whether the 22-year aggregate sentence was unauthorized or contrary to law	State: individual terms and aggregate sentence are within statutory ranges	Glaze: aggregate sentence disproportionate/excessive and contravenes sentencing principles	Each term is statutorily authorized; aggregate sentence is lawful and affirmed

Strickland v. Washington, 466 U.S. 668 (ineffective assistance test: deficient performance and prejudice)
State v. Madrigal, 87 Ohio St.3d 378 (Ohio adoption of Strickland standard for guilty-plea context)
State v. Underwood, 124 Ohio St.3d 365 (agreement between state and defendant bars appeal of an authorized, jointly recommended sentence)