State v. Muhire, 2022 Ohio 3078

Defendant Jean Bosco Muhire, a Rwandan refugee whose first language is Kinyarwanda, was charged with multiple offenses and accepted a plea deal to one count of assault; other charges were dismissed.
The arraignment entry contained an “Order Interpreter – Swahili,” but no interpreter was present at the March 8, 2018 plea hearing; Muhire did not request an interpreter and indicated at the plea hearing that he understood the court’s immigration advisement and then pled guilty and was sentenced.
Muhire later sought to withdraw his plea (filed Aug. 18, 2020), claiming (1) limited English prevented a knowing, voluntary plea and the court should have appointed an interpreter, and (2) trial counsel was ineffective for failing to advise him in a language he understood about immigration consequences.
At the evidentiary hearing, Muhire testified (through a Kinyarwanda interpreter) that he had limited English and did not understand the plea; trial counsel Melissa Pfahler and probation officer Stephanie Jackson testified Muhire communicated adequately in English, counsel discussed the plea and immigration language, and Muhire never requested an interpreter.
The trial court found Muhire understood English and that counsel’s performance was not deficient; the court denied the motion to withdraw the plea, and the appellate court affirmed, holding no abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a foreign-language interpreter was required at plea hearing	Trial court properly assessed Muhire’s English ability; Muhire did not request an interpreter and indicated he understood the advisals	Muhire lacked sufficient English; absence of interpreter rendered plea unknowing/invalid	No — no abuse of discretion; record showed Muhire understood English and did not request interpreter
Whether counsel was ineffective for failing to advise about immigration consequences	Counsel advised Muhire that pleading guilty might carry immigration risks and reviewed plea-form language; immigration consequences for assault were not clear-cut so advising risk was sufficient	Counsel failed to advise in a language Muhire understood and did not adequately warn of deportation risk; would have gone to trial otherwise	No — counsel’s performance not shown deficient; because assault may or may not be a deportable crime, advising that immigration consequences might result satisfied Padilla duty

Padilla v. Kentucky, 559 U.S. 356 (defense counsel must advise noncitizen clients of clear deportation consequences)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance standard)
State v. Xie, 62 Ohio St.3d 521 (trial-court abuse-of-discretion review on post-sentence plea-withdrawal motions)
State v. Bozso, 162 Ohio St.3d 68 (recognizing complexity of immigration consequences and when Padilla requires more specific advice)
Lovano v. Lynch, 846 F.3d 815 (6th Cir.) (explaining moral-turpitude analysis for assault offenses)
State v. Smith, 49 Ohio St.2d 261 (burden on defendant to show manifest injustice to withdraw plea)
State v. Bradley, 42 Ohio St.3d 136 (Strickland framework as adopted in Ohio)
State v. Hale, 119 Ohio St.3d 118 (prejudice standard under Strickland)
Darmond v. State, 135 Ohio St.3d 343 (abuse-of-discretion defined)
AAAA Enterprises, Inc. v. River Place Community Urban Redevelopment Corp., 50 Ohio St.3d 157 (what constitutes an unreasonable decision supporting abuse of discretion)