State v. Jackson, 2013 Ohio 783

In 2001, Jackson pled guilty to murder and received 15 years to life in prison.
He did not file a direct appeal after the plea.
In May 2012, Jackson moved under Crim.R. 32.1 to withdraw the guilty plea, claiming he was not informed that pleading guilty waived jury trial rights and proof beyond a reasonable doubt.
The motion included only an unauthenticated page of transcript attached to the motion.
The trial court denied the motion; Jackson appealed, challenging denial and arguing manifest injustice.
The Ninth District affirmed, holding the post-sentence withdrawal motion requires manifest injustice and substantial evidentiary support; the delay weighed against credibility, and the incomplete transcript failed to demonstrate a constitutional defect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused its discretion denying without a hearing	Jackson argues denial without a hearing was error.	Brown supports no hearing is required without substantial evidence.	No abuse; no hearing needed
Whether the plea was constitutionally infirm for not informing waiver of rights	Jackson was not advised that pleading guilty waived jury trial and proof beyond a reasonable doubt.	Incomplete transcript insufficient to show manifest injustice.	Assignment of error overruled; plea not infirm

State v. Brown, 9th Dist. No. 24831, 2010-Ohio-2328 (Ohio 2010) (post-sentence withdrawal requires manifest injustice standard)
State v. Smith, 49 Ohio St.2d 261 (1977) (undue delay weighs against movant regarding Crim.R. 32.1 motions)
State v. McKinney, 9th Dist. No. 06CA0031-M, 2006-Ohio-5364 (Ohio 2006) (inadequate evidentiary submission may foreclose a hearing)