State v. Hill, 218 N.E.3d 891

Davis Hill was indicted on multiple drug counts with major-drug-offender specifications and two weapons-under-disability counts; he moved to suppress evidence and the trial court denied those motions.
During plea negotiations the state offered a recommended sentence (16 to 21.5 years) conditioned on Hill pleading guilty; the state “heavily objected” to a no-contest plea.
The trial judge stated she rarely accepts no-contest pleas and would refuse Hill’s request because she saw no legitimate appellate issues and felt her suppression rulings were correct.
Hill then pleaded guilty and received the state’s recommended sentence; the Fifth District affirmed, finding no blanket refusal to accept no-contest pleas.
The Ohio Supreme Court held the trial court abused its discretion by denying Hill’s requested no-contest plea on the ground that the court itself found no appealable issues—thus substituting its own appellate review—and reversed and remanded to permit a new plea under Crim.R. 11.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hill)	Held
Whether the trial court abused its discretion by refusing a no-contest plea because it believed there were no legitimate issues to preserve for appeal	Trial court acted within discretion; it did not apply a blanket policy and reasonably concluded no appealable issues existed	Trial court effectively applied a blanket policy and substituted its judgment for the court of appeals, unlawfully denying Hill the ability to preserve suppression issues on appeal	Court held trial court abused its discretion by reviewing and resolving the appealable issues itself; reversal and remand to allow new plea under Crim.R. 11

State v. Beasley, 97 N.E.3d 474 (Ohio 2018) (trial-court blanket refusal to accept no-contest pleas is an abuse of discretion)
State v. Jenkins, 473 N.E.2d 264 (Ohio 1984) (standard: trial-court refusal to accept plea reviewed for abuse of discretion)
Blakemore v. Blakemore, 450 N.E.2d 1140 (Ohio 1983) (abuse of discretion defined as unreasonable, arbitrary, or unconscionable)
State v. Xie, 584 N.E.2d 715 (Ohio 1991) (discussing liberal standard for pretrial plea-withdrawal motions and contrasts with Crim.R. 11 consent requirement)