State v. Jackson, 2021 Ohio 3070

Two consolidated Clermont County cases from events on Feb. 11, 2020: shoplifting, then a Food Mart robbery where appellant pointed a pellet/BB gun that looked like a .357 at a cashier.
High-speed police chase followed (speeds up to 94 mph), appellant wrecked vehicle; police recovered cocaine and a fentanyl-related compound in the car.
Indictments included aggravated robbery, robberies, failure to comply, theft, multiple OVIs, and drug-possession counts; repeat violent-offender specifications were charged.
Pursuant to plea deal, appellant pled guilty to aggravated robbery (1st° felony), failure to comply (3rd° felony), OVI (misdemeanor), and possession of fentanyl-related compound (4th° felony); other counts and specifications dismissed.
Trial court sentenced: aggravated robbery an indefinite term 10–15 years; concurrent terms of 36 months (failure to comply), 18 months (possession), and 180 days (OVI), with the latter concurrent to each other but consecutive to aggravated robbery.
On appeal, Jackson argued (1) he was promised minimum prison terms as part of the plea and (2) ineffective assistance of counsel for allegedly promising minima and failing to argue or object at sentencing.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jackson)	Held
Whether Jackson was promised minimum prison terms in exchange for his guilty pleas	No promise was made; plea forms and record show only dismissals as consideration	Jackson contends counsel and plea understanding promised minimum terms	Court: No record support for promised minima; appellant failed to provide plea transcript; presumes regularity and overrules claim
Whether counsel provided ineffective assistance at plea/sentencing	Counsel's performance not shown deficient; even if counsel made representations, defendant cannot show reasonable probability of a different outcome	Counsel allegedly promised minima and failed to argue for minima or object to sentence disproportionality	Court: Strickland not satisfied — performance and prejudice not shown; sentencing within statutory range and justified by seriousness, harm, and criminal history; claim overruled

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged test for ineffective assistance: deficient performance and prejudice)
State v. Williams, 73 Ohio St.3d 153 (Ohio 1995) (appellant bears burden to ensure record on appeal contains transcripts necessary for review)
Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (Ohio 1980) (when necessary portions of the transcript are omitted, reviewing court will presume regularity of proceedings)