State v. King, 2019 Ohio 3167

Jamarr King was indicted on drug and related counts; supplemental indictment added manslaughter and multiple trafficking charges. He pled not guilty initially.
On the day of trial, King accepted a plea: he pleaded guilty to multiple trafficking counts; the State dismissed involuntary manslaughter and two corrupting-with-drugs counts. No sentencing agreement was made.
King later filed a pro se pre-sentence motion to withdraw his guilty plea, claiming actual innocence and that counsel misled him into believing he would receive "straight probation."
The trial court held a hearing on the motion, questioned King about his understanding of the plea (including that there was no promise of probation), and denied the motion.
At sentencing the court imposed concurrent terms totaling three years’ imprisonment. King appealed the denial of his motion to withdraw his plea.

Issue	King’s Argument	State’s Argument	Held
Whether the trial court abused its discretion by denying King’s pre-sentence motion to withdraw his guilty plea	King argued the plea was not voluntary/knowing because counsel led him to believe he would receive straight probation and he was pressured into a last-minute plea	State argued King was represented by experienced counsel, was informed on the record that probation was not part of the agreement, and was given chance to consult counsel	Court held no abuse of discretion; denial affirmed

State v. Xie, 62 Ohio St.3d 521 (1992) (sets standard that presentence withdrawal motions should be freely allowed but not absolute; trial court has discretion and must hold a hearing)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (defines "abuse of discretion" as unreasonable, arbitrary, or unconscionable)