State v. Jackson, 2024 Ohio 2599

McKinley Jackson was indicted on four counts, including attempted murder and felonious assault with a repeat violent offender specification.
He entered into a plea agreement, pleading guilty to one count of felonious assault; all other counts were dismissed.
At sentencing, Jackson attempted to withdraw his guilty plea, alleging ineffective assistance by his public defenders but initially decided not to do so after consulting with counsel.
The appellate court previously found that the trial court improperly induced Jackson to abandon his withdrawal due to a blanket policy against renewed pleas and remanded for a new hearing.
On remand, Jackson renewed his motion to withdraw his guilty plea before sentencing, citing lack of discovery and attorney ineffectiveness.
The trial court denied the motion, finding no credible basis beyond a change of heart, and the denial was affirmed on appeal.

Issue	Appellant's Argument	State's Argument	Held
Whether the trial court erred in denying Jackson’s motion to withdraw his guilty plea before sentencing	Claimed ineffective assistance (failure to review evidence, investigate, or advise correctly); discovered new evidence post-plea	Counsel was competent, discovery given, and all key evidence discussed; no substantive new evidence; plea was knowing and voluntary	Denial affirmed; no abuse of discretion; no legitimate basis for withdrawal

State v. Xie, 62 Ohio St.3d 521 (Ohio 1992) (court discretion to grant or deny presentence plea withdrawal, must hold hearing for reasonable and legitimate basis)
State v. Peterseim, 68 Ohio App.2d 211 (Ohio Ct. App. 1980) (four-factor test for evaluating motion to withdraw plea)
State v. Strickland, 466 U.S. 668 (standard for ineffective assistance of counsel)
State v. Bradley, 42 Ohio St.3d 136 (objective standard for counsel's performance and required prejudice for claim)