2020 Ohio 895
Ohio Ct. App.2020Background:
- Robert Jacobs pleaded guilty in early 2019 to involuntary manslaughter and attempted murder for a shelter shooting that killed one person and seriously wounded another; the plea resolved other charges, including aggravated murder, and produced a 26-year sentence.
- Jacobs later appealed, arguing his pleas were involuntary because the trial court denied his request for a continuance, which he says coerced him into pleading.
- At the plea hearing Jacobs stated he felt "bombarded," wanted a new lawyer, and said he did not have sufficient time to consider the plea; the court offered him another day, offered to stop the hearing, and reiterated that he could proceed to trial.
- Jacobs declined the continuance and affirmed his desire to enter the guilty pleas; he also declined to elaborate on an unspecified "incident" with counsel but told the court he was otherwise satisfied with his attorney.
- The trial court conducted a Crim.R. 11 colloquy; the appellate court reviewed the record, compared similar precedent, and found no indicia of coercion.
- The First District affirmed Jacobs’s convictions, holding the pleas were entered knowingly, voluntarily, and intelligently.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jacobs’s guilty pleas were involuntary/coerced by denial of a continuance | State: Pleas were knowing, voluntary; court complied with Crim.R.11 and offered continuance and trial option | Jacobs: Denial of continuance and feeling "bombarded" coerced him into pleading; referenced an "incident" with counsel | Court: Pleas were voluntary; court offered time/options, no evidence counsel coerced or threatened, Crim.R.11 satisfied; conviction affirmed |
Key Cases Cited
- State v. Engle, 660 N.E.2d 450 (Ohio 1996) (guilty plea valid only if knowing, voluntary, and intelligent)
- State v. Nero, 564 N.E.2d 474 (Ohio 1990) (Crim.R.11 adopted to ensure adequate record of plea voluntariness)
- State v. White, 81 N.E.3d 958 (Ohio App. 2017) (plea induced by promises or threats that deprive it of voluntariness is void)
- State v. Danon, 105 N.E.3d 596 (Ohio App. 2018) (denial of continuance not coercive where court offered time and Crim.R.11 compliance exists)
- State v. Foster, 121 N.E.3d 76 (Ohio App. 2018) (plea must be entered knowingly, voluntarily, intelligently)
- State v. Wiesenborn, 135 N.E.3d 812 (Ohio App. 2019) (compliance with Crim.R.11 creates presumption plea was knowing, intelligent, and voluntary)