State v. Monaco
2021 Ohio 3888
| Ohio Ct. App. | 2021Background
- Jason D. Monaco was indicted on multiple sexual-offense counts, including rape, kidnapping, gross sexual imposition, and offenses involving child pornography.
- On October 21, 2020, after signing a Crim.R. 11 change-of-plea form and a plea colloquy, Monaco pled guilty pursuant to an agreed recommendation producing an aggregate sentence of 15 years to life.
- The trial court advised Monaco of the charges, penalties, and constitutional rights; Monaco acknowledged understanding and knowingly pleaded guilty.
- Monaco filed a pro se post-sentence motion to withdraw his guilty plea, claiming duress, extreme depression and anxiety, and inadequate review of discovery with counsel.
- At a hearing the court heard Monaco’s uncorroborated assertions; no medical or professional evidence was offered to substantiate mental-impairment claims.
- The trial court denied the post-sentence Crim.R. 32.1 motion; the court of appeals affirmed, holding Monaco failed to show "manifest injustice."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion denying a post-sentence Crim.R. 32.1 motion to withdraw a guilty plea | State: Monaco failed to show "manifest injustice." His plea was knowing, voluntary, and intelligent; allegations of depression/anxiety were uncorroborated and self-serving. | Monaco: Plea was involuntary due to duress, extreme depression and anxiety; counsel did not sufficiently review discovery; therefore post-sentence withdrawal is warranted. | Court affirmed. Denial was not an abuse of discretion—Monaco did not meet the high "manifest injustice" standard; self-serving claims without corroboration insufficient. |
Key Cases Cited
- State v. Smith, 49 Ohio St.2d 261 (1977) (post-sentence plea-withdrawal under Crim.R. 32.1 is reviewed for abuse of discretion and allowed only to correct manifest injustice)
- State v. Francis, 104 Ohio St.3d 490 (2004) (appellate review standard for trial-court discretionary rulings in plea-withdrawal context)
- Berk v. Matthews, 53 Ohio St.3d 161 (1990) (appellate courts will not substitute their judgment for trial court under abuse-of-discretion review)