State v. Harrison, 2020 Ohio 4154

On Jan. 26, 2019 Harrison fired at a Mercury Milan that had been stolen by a juvenile (T.S.); during the episode another juvenile (R.A.) was later run over and suffered life‑threatening injuries.
Police arrested Harrison; he admitted shooting at the car. Searches were executed and Harrison was indicted on multiple counts (felonious assault, firearm specifications, improperly discharging a firearm, tampering with evidence, having a weapon while under disability).
A separate jail altercation produced an additional felonious‑assault charge; Harrison later pled guilty in that case and the parties discussed a “global” resolution covering both indictments.
At plea hearings the trial judge repeatedly told the parties she was not bound by any agreement, would only hold sentencing in abeyance until the August trial date, and stated she would not accept a three‑year agreed sentence but indicated willingness to accept a 20‑year aggregate sentence.
Harrison pled guilty in both cases to multiple counts with the parties agreeing to a 15–20 year global mandatory range; the court imposed an aggregate 20‑year prison term and restitution and costs.
On appeal Harrison argued the court improperly intervened in plea negotiations and thereby rendered his pleas not knowing, intelligent, and voluntary; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial judge’s statements about sentence range and docket control improperly coerced or invalidated Harrison’s guilty pleas	State: court may comment and reject agreed sentence; it is not bound by plea agreements and may insist parties run proposals by the court	Harrison: judge’s active statements and warnings pressured him to plead and made plea involuntary	Court: No coercion. Judge merely clarified she was not bound by parties’ agreement, controlled docket, and expressed sentencing inclination; plea remained knowing, intelligent, voluntary

Boykin v. Alabama, 395 U.S. 238 (holding a guilty plea must be knowing, intelligent, and voluntary)
State v. Byrd, 63 Ohio St.2d 288 (1980) (trial judge’s partisan advocacy of a plea can render a plea coerced)
In re Disqualification of Forchione, 155 Ohio St.3d 1254 (2018) (Ohio Supreme Court: judicial participation in plea negotiations is strongly discouraged)
State v. Underwood, 124 Ohio St.3d 365 (2010) (trial court is not bound by a plea agreement unless the court agrees to the terms)