State v. Jackson, 2023 Ohio 762

Jackson was indicted on four felonies, including attempted murder and multiple counts of felonious assault with a repeat violent-offender specification.
He accepted a plea agreement to plead guilty to one felonious assault count in exchange for dismissal of the other counts.
At the change-of-plea hearing the court found the plea knowing, intelligent, and voluntary and accepted it.
Before sentencing Jackson sent a letter and then orally stated at sentencing that he wanted to withdraw his guilty plea.
The trial judge told Jackson the court had a blanket policy of not accepting more than one plea from the same defendant in the same case, warned that if Jackson withdrew his plea he would never be allowed to plea again, and Jackson then chose not to withdraw.
The court imposed indefinite consecutive sentences; on appeal the Eleventh District reversed and remanded, holding the court’s blanket-policy statement coerced Jackson’s decision and rendered the plea involuntary, and ordered a hearing on his motion to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s statement of a blanket policy refusing to accept more than one plea coerced Jackson’s decision not to withdraw his plea	The State argued the court properly refused to accept repeated pleas and acted within discretion	Jackson argued the court’s blanket policy and threat that it would "never" accept another plea coerced him and made his plea involuntary	The court held the blanket policy was arbitrary, coerced Jackson’s decision, and rendered the plea involuntary; reversed and remanded for a withdrawal-hearing
Whether Jackson’s challenge to his indefinite Reagan Tokes sentence required relief	The State maintained sentence was lawful	Jackson argued the indefinite sentence was unconstitutional under Reagan Tokes or otherwise defective	The court found this issue moot because reversal was required on the coercion/plea issue

State v. Xie, 62 Ohio St.3d 521 (presentence motion to withdraw plea should be liberally considered; review for abuse of discretion)
Santobello v. New York, 404 U.S. 257 (pleas must be upheld consistent with promises and prosecutorial/ judicial conduct)
State v. Beasley, 152 Ohio St.3d 470 (blanket refusal to accept pleas is arbitrary and an abuse of discretion)
Machibroda v. United States, 368 U.S. 487 (pleas induced by threats or promises that negate voluntariness are void)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (standard for abuse of discretion)
Akron v. Ragsdale, 61 Ohio App.2d 107 (trial court should state reasons when rejecting plea bargains)
State v. Engle, 74 Ohio St.3d 525 (guilty pleas must be knowing, intelligent, and voluntary)
State v. Veney, 120 Ohio St.3d 176 (constitutional requirement that pleas be knowing, intelligent, voluntary)