State v. Massey, 2015 Ohio 4711

Massey participated in extracting a car from a cornfield with Charles Alexander and Rickey Johnson; afterwards several items were taken from a nearby barn and sold.
Massey initially admitted in writing and orally to police and a probation officer that he stole the items; he later claimed he falsely confessed to protect Alexander.
Indicted for fifth-degree felony Theft and Breaking & Entering; State agreed to dismiss Breaking & Entering in exchange for a guilty plea to Theft and recommended community control.
At a thorough Crim.R. 11 plea hearing Massey pled guilty and shortly thereafter repeated an admission during a presentence interview.
Five weeks after pleading, and two weeks before sentencing, Massey moved to withdraw his guilty plea asserting innocence; the trial court held a hearing, considered testimony (including Johnson’s), and issued a written decision applying nine Fish factors to deny the motion.
The trial court concluded Massey’s request was a change of heart, not based on new evidence, and did not abuse its discretion; this Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying a pre‑sentence motion to withdraw a guilty plea	State: Massey offered no reasonable, legitimate basis to withdraw; plea was knowing and voluntary and supported by admissions	Massey: He is actually innocent; he only pled to protect Alexander and later recanted after learning Alexander lied about custody	Court: No abuse of discretion — denial affirmed: motion was a change of heart, not new evidence; Fish factors support denial

State v. Xie, 62 Ohio St.3d 521 (pre‑sentence plea withdrawal should be freely and liberally granted but defendant must show a reasonable and legitimate basis)
State v. Fish, 104 Ohio App.3d 236 (enumeration of nine factors for evaluating pre‑sentence plea withdrawal)