State v. Ingram, 93 N.E.3d 1253

Denver Ingram was indicted on seven counts including trafficking, child endangerment, illegal manufacture/assembly of drugs, and RICO-type corrupt activity; indictment alleged methamphetamine manufacture and sales near a juvenile and an elementary school.
Appointed counsel was provided after Ingram was found indigent; months later he expressed a desire to retain a paid lawyer but did not identify a conflict with appointed counsel.
On September 15, 2016, Ingram pleaded guilty to two third-degree aggravated trafficking counts; remaining counts were dismissed; court sentenced him to consecutive 36‑month terms (total 72 months).
After sentencing Ingram filed a delayed appeal raising three grouped assignments of error: (1) deprivation of right to retain counsel of choice, (2) unconstitutional "trial tax"/prosecutorial vindictiveness coercing plea, and (3) violation of statutory speedy-trial rights applicable to incarcerated defendants (R.C. 2941.401 / 2945.71).
The trial court conducted Crim.R. 11 colloquy, recessed to allow consultation with appointed counsel, and Ingram affirmed satisfaction with counsel and that his plea was knowing and voluntary.

Issue	Ingram's Argument	State's Argument	Held
Right to retain counsel of choice	Trial court denied his right to hire a paid lawyer and forced appointed counsel	Court properly appointed counsel for indigent defendant; right to choice not absolute for appointed counsel	No violation; defendant didn’t show timely, specific conflict or deprivation; plea entered knowingly and voluntarily
"Trial tax" / coercion of plea	Court threatened harsher sentence if he sought new counsel or went to trial, coercing plea	Court’s comments explained risks and options; warning about potential greater exposure is permissible	No unconstitutional trial tax; remarks explained consequences and did not coerce plea
Prosecutorial vindictiveness	Plea offer and court remarks were vindictive punishment for asserting rights	Plea bargaining and explanation of reduced exposure are permissible; no presumption of vindictiveness	No presumption or clear evidence of vindictiveness; prosecutor reduced exposure by plea offer
Speedy-trial under R.C. 2941.401 / 2945.71	Statutory speedy-trial rights (as an incarcerated defendant) were violated	By pleading guilty, defendant waived statutory speedy-trial objections unless plea was involuntary	Waived: guilty plea was found voluntary and knowing, so speedy-trial claim forfeited

Gideon v. Wainwright, 372 U.S. 335 (1963) (indigent defendants are entitled to appointed counsel)
United States v. Gonzalez-Lopez, 548 U.S. 140 (2006) (right to retained counsel of choice does not extend to appointed counsel)
Wheat v. United States, 486 U.S. 153 (1988) (limits on choice of counsel and trial-court management of counsel substitutions)
Morris v. Slappy, 461 U.S. 1 (1983) (right to effective counsel does not guarantee counsel of choice)
Bordenkircher v. Hayes, 434 U.S. 357 (1978) (prosecutor may offer plea bargains that highlight harsher consequences of going to trial)
North Carolina v. Pearce, 395 U.S. 711 (1969) (due process violation where harsher sentence imposed in retaliation for exercising trial rights)
United States v. Goodwin, 457 U.S. 368 (1982) (presumption of prosecutorial vindictiveness requires a reasonable likelihood of vindictiveness)
State v. O'Dell, 45 Ohio St.3d 140 (1989) (defendant should not be punished for exercising right to trial)
State v. Rahab, 150 Ohio St.3d 152 (2017) (appellate reversal permitted where clear and convincing evidence shows a sentence based on actual vindictiveness)