State v. Maddox
2022 Ohio 1350
| Ohio Ct. App. | 2022Background
- Edward Maddox entered Alford pleas to two counts of attempted burglary (third-degree felonies) and one count of burglary (second-degree felony).
- At sentencing under the Reagan Tokes Act (Am.Sub.S.B. No. 201), the trial court imposed concurrent terms: 12 months on each attempted-burglary count and an indefinite term of 4–6 years on the burglary count.
- Maddox appealed, arguing (1) the Reagan Tokes presumptive-release provision (R.C. 2967.271) is unconstitutional and (2) trial counsel was ineffective for not objecting to its application.
- This Court initially declined to reach the constitutional issue as not ripe; the Ohio Supreme Court reversed and remanded, directing this Court to decide the constitutionality question.
- The Sixth District adopted the dissenting opinion from State v. Wolfe and concluded R.C. 2967.271 does not violate the right to jury trial, due process, or separation of powers; the court affirmed Maddox’s sentence.
- Because the statute was held constitutional, the court rejected the ineffective-assistance claim for lack of prejudice under Strickland.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Maddox) | Held |
|---|---|---|---|
| Constitutionality of R.C. 2967.271 (presumptive release) | Statute is constitutional; supervisorial/administrative parole-type review does not violate jury trial, due process, or separation of powers | Presumptive-release feature delegates judicial sentencing power, violates jury trial and due process, and breaches separation of powers | Court upheld the statute as constitutional, adopting the Wolfe dissent reasoning |
| Ineffective assistance for not challenging R.C. 2967.271 at trial | No prejudice because statute is constitutional; counsel presumed competent | Counsel was deficient for failing to object to an unconstitutional sentencing regime | Claim denied: no prejudice shown, so Strickland/Bradley standard not met |
Key Cases Cited
- North Carolina v. Alford, 400 U.S. 25 (1970) (guilty plea while maintaining innocence may be accepted)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
- State v. Hamblin, 37 Ohio St.3d 153 (1988) (attorney is presumed competent)
- State v. Bradley, 42 Ohio St.3d 136 (1989) (Ohio adopts Strickland standard for ineffective assistance)