State v. Mejia, 2020 Ohio 6870

Appellant Lucas Mejia was indicted on three counts for sexual offenses against a 12‑year‑old; he pleaded guilty to Count 1 (rape under R.C. 2907.02(A)(1)(b) and (B)) in exchange for dismissal of Counts 2 and 3.
The indictment’s Count 2 explicitly alleged the victim was “purposely compelled… by force or threat of force,” but Count 1 (the plea count) contained no force specification.
At plea and sentencing the trial court stated a 25‑years‑to‑life prison term was mandatory and imposed that sentence; the record is silent regarding any finding or proof that force was used.
Appellant appealed, raising ineffective‑assistance claims (failure to move to suppress; failure to advocate for lesser sentence) and arguing the 25‑to‑life sentence was contrary to law.
The appellate court held the ineffective‑assistance claim about a suppression motion failed because relevant suppression materials were not in the record, but concluded the 25‑to‑life sentence was contrary to law because R.C. 2971.03(B)(1)(c) (which authorizes 25‑to‑life) requires an allegation/finding of force (or another statutory predicate) that was absent in Count 1 and the record.
The court reversed and remanded for resentencing under the applicable statutory range (i.e., the R.C. 2971.03(B) options applicable to a defendant convicted under R.C. 2907.02(A)(1)(b)).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to file a motion to suppress, rendering plea involuntary	Mejia: counsel should have moved to suppress custodial statements; absent suppression he would not have pled	State: suppression evidence not in record; no showing counsel was deficient or prejudice	Not ineffective — record lacks suppression evidence; claim fails under Strickland/Hill standard
Whether 25‑years‑to‑life sentence was authorized for plea to R.C. 2907.02(A)(1)(b) rape	Mejia: sentence contrary to law because no force finding or other R.C. 2971.03(B)(1)(c) predicate for 25‑to‑life	State: argues force may be inferred from record/case law on authority/child victims	Sentence contrary to law — 25‑to‑life under R.C. 2971.03(B)(1)(c) requires allegation/finding of force (or other listed predicate) which was absent; reverse and remand

Strickland v. Washington, 466 U.S. 668 (ineffective‑assistance standard for counsel performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (prejudice standard for ineffective assistance in guilty‑plea cases)
Lee v. United States, 137 S. Ct. 1958 (courts may predict likely trial outcome when counsel error affects decision to plead)
State v. Eskridge, 38 Ohio St.3d 56 (force can be implied in parent‑child context; psychological coercion)
State v. Dye, 82 Ohio St.3d 323 (person in position of authority over child under 13 may be convicted of rape with force absent overt threat)
State v. Bradley, 42 Ohio St.3d 136 (Ohio standard applying Strickland)
State v. Ketterer, 111 Ohio St.3d 70 (application of Hill to guilty‑plea ineffective‑assistance claims)