State v. Leonard, 2017 Ohio 8421

On Aug. 26, 2015, Thomas E. Leonard drove a Ford F-350 at high speed on I-75, weaving, driving on shoulders/rumble strips, and striking multiple vehicles before colliding with a disabled Audi in the emergency lane; the Audi’s driver, Mitchell Munoz, was killed.
Post-crash testing showed cocaine and opiates in Leonard’s blood; crash reconstruction estimated Leonard’s pre-impact speed at 108–117 mph and the Audi’s post-impact speed at 49–54 mph; no braking was observed before impact.
Leonard was indicted for aggravated vehicular homicide (third-degree felony) and faced up to 60 months, fines, license suspension, restitution, and costs.
Defense counsel requested extensive discovery (crash reports, reconstruction, photos, videos, coroner materials) and sought continuances; no plea agreement was reached with the State.
Leonard pleaded guilty on Nov. 9, 2016, with no sentencing agreement; the court ordered a PSI and sentenced him to 48 months’ imprisonment and a 10-year license suspension on Dec. 16, 2016.
On appeal Leonard claimed ineffective assistance of counsel for (1) failing to file motions beyond discovery and (2) advising him to plead guilty without a plea deal; the trial court record and PSI supported the State’s factual presentation and the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel rendered ineffective assistance by filing few motions	State: counsel conducted reasonable investigation and discovery; no deficient conduct shown	Leonard: counsel did only one document and otherwise failed to litigate pretrial issues	Court: no deficient performance shown; defendant did not identify omitted motions or explain prejudice
Whether counsel was ineffective in advising plea without plea agreement	State: plea was knowing, intelligent, voluntary; counsel’s advice (if any) was reasonable given strong evidence	Leonard: counsel advised him to plead guilty notwithstanding no sentencing or charge concessions	Court: plea colloquy shows voluntariness; defendant failed to show reasonable probability he would have gone to trial; counsel’s strategy was reasonable given discovery and reconstruction evidence

Strickland v. Washington, 466 U.S. 668 (constitutional standard for ineffective assistance of counsel)
Hill v. Lockhart, 474 U.S. 52 (prejudice standard for guilty-plea ineffective-assistance claims)
State v. Bradley, 42 Ohio St.3d 136 (Ohio adoption of Strickland framework)
State v. Cook, 65 Ohio St.3d 516 (debatable trial strategy does not establish ineffective assistance)