State v. Grant, 2023 Ohio 4614

Joshua Grant was indicted on five counts of rape, one count of attempted rape, and one count of gross sexual imposition in Muskingum County, Ohio.
Grant entered Alford pleas to four amended counts of gross sexual imposition, all felonies of the fourth degree.
In exchange for his plea, the state dismissed the remaining charges, reducing Grant’s maximum sentencing exposure from approximately ninety-six years to six years.
Grant was sentenced to four consecutive 18-month prison terms (total 72 months) after the trial court reviewed a PSI, considered various factors, and heard from the parties and Grant.
Grant's appellate counsel sought to withdraw under Anders v. California, asserting no non-frivolous appealable issues existed; Grant did not file a pro se brief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Alford Plea	Plea entered knowingly, intelligently, and voluntarily; met procedural requirements	No argument—counsel asserts no non-frivolous issue	Plea was valid and complied with Criminal Rule 11
Voluntariness of Plea	No coercion, proper advisement of rights and consequences	No argument—counsel asserts no non-frivolous issue	Plea was not coerced; entered knowingly/voluntarily
Consecutive Sentencing	Sentencing adhered to statutory findings and considered necessary factors	No argument—counsel asserts no non-frivolous issue	Consecutive sentences supported by record and law
Existence of Non-Frivolous Appeal Issues	No meritorious issues for appeal	No argument—counsel asserts no non-frivolous issue	Appeal is wholly frivolous, motion to withdraw granted

Anders v. California, 386 U.S. 738 (sets procedure for withdrawal when counsel finds appeal wholly frivolous)
North Carolina v. Alford, 400 U.S. 25 (establishes Alford plea—guilty plea with protestations of innocence)
State v. Piacella, 27 Ohio St.2d 92 (Ohio law on standards for accepting an Alford plea)