State v. Johnson, 2019 Ohio 4595

Hayes Junior Johnson was indicted on multiple charges after an attempted vehicle theft at Fischer Auto Sales, including one count of third-degree-felony robbery; the State alleged he threatened the owner, damaged multiple vehicles (~$5,000), and fled in a stolen vehicle.
Johnson was on community/post-release control when the offense occurred, posted bond but failed to appear for trial and was later arrested on a capias for bond violation.
He entered a plea agreement, pleading guilty to robbery in exchange for dismissal of the other counts; he stipulated to a 717-day enhancement for a post-release control violation and agreed to $5,000 restitution.
The trial court declined a new PSI but obtained prior PSI reports and other documents, considered those materials and victim statements, and conducted a sentencing hearing.
The court imposed the maximum authorized term for a third-degree felony (36 months) plus the 717-day enhancement and ordered restitution. Johnson appealed, raising (1) that the court failed properly to apply R.C. 2929.12 and improperly imposed the maximum sentence, and (2) that the court erred in denying his motion to appoint new trial counsel.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Johnson)	Held
Whether the 36-month sentence is contrary to law / unsupported by the record	Trial court considered R.C. 2929.11/2929.12, reviewed prior PSIs and victim evidence; sentence is within statutory range and lawful	Court failed to consider mitigating factors (no weapon, no physical injury, apology, only $5,000 damage) and record does not support maximum term	Affirmed: court expressly considered sentencing statutes and factors; sentence within statutory range and not clearly unsupported by record
Whether trial court abused discretion by denying motion to appoint new counsel	Trial court found no breakdown in attorney-client relationship; counsel conveyed plea offers and evaluated mental health issues; denial was proper	Counsel failed to convey a plea offer and refused to raise Johnson’s drug/alcohol/mental-health issues, warranting new counsel	Affirmed: no abuse of discretion; no transcript of hearing (presumption of valid proceedings); strategic disagreements don’t require substitution

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (standard of appellate review under R.C. 2953.08(G)(2))
State v. Mathis, 846 N.E.2d 1 (Ohio 2006) (trial court must consider R.C. 2929.11 and 2929.12 when sentencing)
State v. Brown, 99 N.E.3d 1135 (Ohio App.) (discussion of when a sentence is contrary to law)
State v. King, 992 N.E.2d 491 (Ohio App.) (trial court has discretion to impose any sentence within statutory range without specific findings)
Knapp v. Edwards Laboratories, 400 N.E.2d 384 (Ohio 1980) (when necessary transcript portions are omitted on appeal, appellate court presumes regularity)
State v. Cowans, 717 N.E.2d 298 (Ohio 1999) (indigent defendant must show good cause to replace appointed counsel)
State v. Murphy, 747 N.E.2d 765 (Ohio 2001) (same principle regarding substitution of counsel)
State v. Coleman, 525 N.E.2d 792 (Ohio 1988) (breakdown in attorney-client relationship standard for substitution)
AAAA Enterprises, Inc. v. River Place Community Urban Redevelopment Corp., 553 N.E.2d 597 (Ohio 1990) (abuse-of-discretion framework: decision unreasonable if no sound reasoning process)
State v. Leopard, 957 N.E.2d 55 (Ohio App.) (trial court must consider statutory purposes and principles of sentencing)