State v. Griffin, 2018 Ohio 60

Calvin Griffin faced multiple indictments (including felonious assault with a drive-by specification and weapons/drug charges) arising from several cases; he ultimately received a total prison term of ten years across the cases.
On August 10, 2012 Griffin pled guilty in several cases; in case No. 12CR-2434 he was sentenced to 4 years for felonious assault plus a consecutive 5-year mandatory drive-by specification (and additional consecutive time from another case), producing a ten-year total.
Griffin appealed one case (12CR-470) and lost; he did not timely appeal the other cases.
Nearly five years after sentencing (March 28, 2017), Griffin filed a post-sentence Crim.R. 32.1 motion to withdraw his guilty plea in case No. 12CR-2434, claiming ineffective assistance because counsel failed to advise him of a prosecution “global” offer to resolve all pending cases for six years.
The State submitted trial transcripts showing multiple plea offers (including an eight-year and a six-year package offer) were placed on the record in Griffin’s presence and that Griffin rejected them; the trial court denied the motion, finding the affidavit contradicted the transcript and no manifest injustice was shown.
The appellate court affirmed, holding the trial court did not abuse its discretion in denying post-sentence withdrawal based on conflicting record evidence and Griffin’s undue delay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying Griffin's post-sentence motion to withdraw his guilty plea based on alleged ineffective assistance for failing to communicate a six-year global plea offer	The State: transcripts show the prosecution placed multiple package offers (including six years) on the record in Griffin's presence and that Griffin rejected them; no manifest injustice exists so withdrawal not warranted	Griffin: counsel failed to competently inform him of a six-year global offer; had he known he would have accepted it, so ineffective assistance caused manifest injustice	Court: Denied. The trial court did not abuse its discretion; transcripts contradict Griffin's affidavit, and undue delay and lack of credible evidence defeat the Crim.R. 32.1 motion

State v. Smith, 49 Ohio St.2d 261 (Ohio 1977) (defendant bears the burden to show manifest injustice for post-sentence plea withdrawal)
State v. Bush, 96 Ohio St.3d 235 (Ohio 2002) (undue delay in filing Crim.R. 32.1 motion undermines movant's credibility and is relevant to relief)