State v. Hoyle, 2016 Ohio 586

Mario Hoyle was indicted in two Cuyahoga County cases charging multiple violent- and drug-related offenses; he ultimately pleaded guilty in September 2014 to drug trafficking (in each case) and failure to comply in one case pursuant to a plea agreement; remaining counts were nolled.
The trial court conducted a full Crim.R. 11 colloquy and accepted Hoyle’s pleas as knowing, intelligent, and voluntary.
Before sentencing Hoyle obtained new counsel and filed a presentence motion to withdraw his guilty pleas, asserting innocence and alleging prior counsel induced the plea through deficient performance (failure to disclose evidence, misstatements about sentence, and fee-motivated representation).
At the withdrawal hearing defense counsel argued discovery showed repeated misidentifications and factual errors that could support an alibi/innocence defense; the prosecutor emphasized accomplice-liability theory and that the record showed a voluntary plea.
The trial court denied the motion to withdraw and later sentenced Hoyle to an aggregate eight-year prison term plus fines and license suspensions. Hoyle appealed both the denial of withdrawal and alleged ineffective assistance of trial counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying Hoyle’s presentence motion to withdraw his guilty pleas	The State argued the plea was knowingly, intelligently, and voluntarily made after a full Crim.R. 11 colloquy and that Hoyle’s post-plea assertions were a change of heart, not a legitimate basis to withdraw.	Hoyle argued discovery showed misidentifications and factual errors supporting innocence/alibi, so he should be allowed to withdraw the plea.	Denial affirmed: court found Hoyle had competent counsel, received a full Crim.R. 11 hearing, had a full withdrawal hearing, and his claimed defenses amounted to attackable evidentiary issues (not a complete defense), i.e., a change of heart.
Whether Hoyle received ineffective assistance of counsel that rendered his plea involuntary	The State maintained counsel’s performance did not fall below reasonable professional norms and the plea transcript shows Hoyle understood the plea and was satisfied with counsel.	Hoyle contended prior counsel withheld evidence, misled him about sentence, and acted for fees, inducing an unknowing/ involuntary plea.	Claim rejected: reviewing court found no objective deficiency in counsel’s performance on the record and no showing that, but for alleged errors, Hoyle would have insisted on trial. Ineffective-assistance claim not proved on direct appeal.

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective assistance standard)
Tollett v. Henderson, 411 U.S. 258 (guilty plea waives many claims except those affecting plea voluntariness)
Hill v. Lockhart, 474 U.S. 52 (prejudice inquiry for plea-related ineffective-assistance claims requires showing defendant would have pleaded not guilty and insisted on trial)
Xie, 62 Ohio St.3d 521 (Ohio standard on presentence motion to withdraw guilty plea and appellate review)
Bradley, 42 Ohio St.3d 136 (counsel performance presumption and standards)
Peterseim, 68 Ohio App.2d 211 (factors supporting denial of plea-withdrawal motion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (abuse-of-discretion standard)