State v. King
2018 Ohio 4780
Ohio Ct. App.2018Background
- Jermaine King was indicted on four counts including attempted rape, two counts of rape, and kidnapping with a sexual-motivation specification.
- King pled guilty to one count of rape (Count 3) in December 2017; remaining counts were nolled. The trial court conducted a Crim.R. 11 colloquy and accepted the plea.
- Before sentencing, King moved to withdraw his guilty plea, alleging he did not fully comprehend the plea because he had been given Zoloft prior to entering it.
- The trial court contacted the jail psychiatric unit, which reported King was compliant with Zoloft and that the medication’s side effects would not cause confusion or drowsiness as claimed.
- At a hearing, defense counsel stated King later told him he did not understand what was happening; the court reviewed the plea colloquy and denied the motion to withdraw, finding the plea knowing, voluntary, and intelligent.
- The court sentenced King to seven years and King appealed the denial of his motion to withdraw the plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion denying a presentence motion to withdraw a guilty plea | State: Trial court properly exercised discretion after full inquiry; plea was valid | King: Plea was not knowing/voluntary because he was medicated (Zoloft) and counsel failed to ensure he understood | Court affirmed: no abuse of discretion; plea was knowing, voluntary, intelligent |
| Whether counsel was ineffective at plea stage | State: Counsel was competent and reviewed the plea with King | King: Counsel failed to evaluate or inform court that King didn’t understand the plea | Court: Record shows counsel reviewed plea and believed King understood; no evidence of incompetence |
| Whether the hearing on the motion to withdraw was incomplete or biased | State: Court held a full, impartial hearing, reviewed colloquy, and consulted psychiatric staff | King: Court relied on medication inquiry and thus did not adequately consider counsel’s concerns | Court: Hearing was complete and impartial; court gave full consideration to arguments and records |
| Whether medication alone renders a plea involuntary | State: Medication presence, without supporting evidence of impairment, does not invalidate plea | King: Zoloft impaired his comprehension at plea | Court: Medical inquiry found no impairment from Zoloft; plea valid despite medication use |
Key Cases Cited
- State v. Xie, 62 Ohio St.3d 521 (1992) (setting standard that presentence plea-withdrawal motions should be freely allowed but require a hearing and review for reasonable legitimate basis)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard defined as unreasonable, arbitrary, or unconscionable)
- State v. Peterseim, 68 Ohio App.2d 211 (1981) (factors supporting denial when defendant had competent counsel, full Crim.R. 11 hearing, full withdrawal hearing, and record shows full consideration)
- State v. Fish, 104 Ohio App.3d 236 (1995) (additional factors to consider on plea-withdrawal such as timing, specificity, understanding of charges, and possible defenses)