State v. Guyton, 2021 Ohio 3725

2009 grand jury indictment charged Justin Guyton with multiple counts including aggravated robbery and firearm specifications; supplemental indictment added counts in 2010.
On May 20, 2010 Guyton signed a written guilty plea to three counts of aggravated robbery and a firearm specification; the State dismissed remaining counts and court sentenced him to 18 years.
Guyton acknowledged in the plea that he waived trial rights, compulsory process, and the right to confront witnesses.
More than a decade later Guyton moved to withdraw his guilty plea, arguing the indictment failed to name a victim and trial counsel was ineffective for not seeking discovery or advising him of the alleged defect.
The State opposed, arguing Guyton failed to show manifest injustice and that he waited over ten years without explanation to seek withdrawal.
The trial court denied the motion; the appellate court affirmed, holding the indictment tracked the statutory language, victim identity is not an essential element, Guyton waived nonjurisdictional defects by pleading, and counsel’s omissions did not meet Strickland standards.

Issue	Guyton's Argument	State's Argument	Held
Whether Guyton can withdraw his guilty plea because the indictment failed to name a victim for aggravated robbery	Indictment defective for not naming a victim; plea involuntary and should be withdrawn	Indictment tracks R.C. 2911.01(A)(1); victim name not an essential element; pleading waived nonjurisdictional defects	Denied — indictment sufficient; plea waiver bars that challenge
Whether trial counsel was ineffective for failing to seek discovery and failing to advise Guyton about the alleged indictment defect	Counsel’s omission precluded a knowing, voluntary plea; that ineffectiveness establishes manifest injustice	Omission was trial strategy; Guyton failed Strickland’s deficient-performance and prejudice prongs and provided no contemporaneous evidence he would have gone to trial	Denied — counsel’s performance not shown deficient; no reasonable probability the plea would have been avoided

Tollett v. Henderson, 411 U.S. 258 (1973) (a voluntary guilty plea waives nonjurisdictional defects and prior-stage constitutional claims)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel: performance and prejudice)
Ross v. Common Pleas Court of Auglaize County, 30 Ohio St.2d 323 (1972) (valid guilty plea by counselled defendant waives nonjurisdictional defects)
Romero v. State, 156 Ohio St.3d 468 (2019) (postconviction assertions about what would have occurred must be supported by contemporaneous evidence)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard for appellate review requires a decision that is unreasonable, arbitrary, or unconscionable)