State v. Holt, 2020 Ohio 6650

On June 4, 2018, Matthew Holt rammed his truck into a teen driver’s car, pursued and struck it again, then struck a parked vehicle at his sister’s home, damaging that vehicle and the garage; officers found Holt intoxicated and threatening the homeowner.
Holt was indicted on five counts; he pled guilty to attempted felonious assault (third-degree felony) and vandalism (fifth-degree felony); remaining counts were dismissed.
The trial court sentenced Holt to 24 months (attempted felonious assault) and 11 months concurrent (vandalism), and ordered payment of court costs and restitution.
Holt was appointed counsel after an indigency hearing and appealed, claiming his trial attorney was ineffective for not moving at sentencing to waive the costs of prosecution.
The court reviewed the claim under the Bradley/Strickland ineffective-assistance framework and considered Ohio precedent allowing courts to impose costs but retain jurisdiction to waive them later.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not moving to waive court costs at sentencing	Holt: counsel failed to request waiver at sentencing despite indigency, mental‑health and employment factors	State: counsel’s timing was trial strategy; counsel raised addiction/mental‑health in mitigation; court found Holt employable; indigency alone insufficient	Court: No ineffective assistance — counsel’s choice was reasonable strategy and Holt showed no prejudice (no reasonable probability costs would have been waived)

State v. Davis, 159 Ohio St.3d 31, 146 N.E.3d 560 (Ohio 2020) (explains waiver authority under R.C. 2947.23 and applies Bradley/Strickland to counsel’s failure to move to waive costs)
State v. Dean, 146 Ohio St.3d 106, 54 N.E.3d 80 (Ohio 2015) (indigency alone does not create reasonable probability court would waive costs)
State v. Conway, 109 Ohio St.3d 412, 848 N.E.2d 810 (Ohio 2006) (trial strategy/tactics do not establish ineffective assistance)
State v. Bradley, 42 Ohio St.3d 136, 538 N.E.2d 373 (Ohio 1989) (adopts Strickland standard for ineffective assistance)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong standard: deficient performance and prejudice)