State v. Haynie
2017 Ohio 8829
Ohio Ct. App.2017Background
- Haynie (resident of CA) was indicted in Ohio on methamphetamine trafficking, RICO (pattern of corrupt activity), and money laundering counts after packages to co-defendant Walter Coffee were traced and bank records showed large deposits/withdrawals tied to Haynie.
- Haynie confessed at proffers to local prosecutor and DEA but declined to identify additional participants.
- Haynie pled guilty to amended indictment (Major Drug Offender spec. dismissed) and was sentenced to an aggregate 16-year prison term on September 26, 2016.
- Haynie did not file a direct appeal; on June 19, 2017 he filed a petition for post-conviction relief alleging innocence and ineffective assistance of trial counsel and seeking an evidentiary hearing.
- The trial court denied the petition without a hearing on July 6, 2017, finding res judicata applied and that Haynie failed to show deficient performance or prejudice; Haynie appealed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Haynie) | Held |
|---|---|---|---|
| Whether trial court erred by denying post-conviction petition without an evidentiary hearing under R.C. 2953.21(E) | Trial court properly denied petition because the record and pleadings do not show entitlement to relief; res judicata bars claims that could have been raised on direct appeal; guilty plea waives most claims | Haynie claimed innocence and ineffective assistance of counsel, argued the petition and affidavits warranted an evidentiary hearing | Court affirmed denial: no abuse of discretion. Res judicata and plea waiver principles bar relief; Haynie failed to allege operative facts showing counsel’s deficient performance caused an unknowing/ involuntary plea |
Key Cases Cited
- Broce v. United States, 488 U.S. 563 (1989) (guilty plea admits commission of acts and waives many appealable errors)
- State v. Powell, 90 Ohio App.3d 260 (1993) (post-conviction relief requires showing of constitutional violation at trial)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard defined)
- State v. Perry, 10 Ohio St.2d 175 (1967) (res judicata bars raising claims that were or could have been raised on direct appeal)
- State v. Calhoun, 86 Ohio St.3d 279 (1999) (petition may be denied without hearing if files and records show petitioner not entitled to relief)
- State v. Cole, 2 Ohio St.3d 112 (1982) (limits on raising ineffective-assistance claims on post-conviction review)
- State v. Jackson, 64 Ohio St.2d 107 (1980) (post-conviction petition not an automatic right to evidentiary hearing)
- State v. Kelley, 57 Ohio St.3d 127 (1991) (guilty plea waives appealable errors unless plea was not knowing and voluntary)