State v. Pames
2022 Ohio 616
Ohio Ct. App.2022Background
- Defendant Cornelius Pames was indicted in four Cuyahoga County cases for multiple violent and sexual offenses arising from incidents in 2018–2019 (including rape, kidnapping, aggravated burglary, murder-related counts, and escape/postrelease-control violations).
- During the rape trial (May 10–12, 2021) Pames accepted a negotiated global plea covering counts in all four cases: 12 total guilty pleas with an agreed aggregate sentencing range of 30–40 years; remaining counts were to be dismissed.
- At the change-of-plea hearing the court conducted a Crim.R. 11 colloquy; Pames affirmed understanding the plea terms, waived rights, and stated he was satisfied with counsel; the court accepted the pleas as knowing and voluntary.
- At sentencing (June 17, 2021), Pames orally sought to withdraw pleas for three of the four cases, claiming he was distracted by news of his father’s cancer and was pressured by his father and counsel to plead guilty; he also submitted an undated handwritten letter.
- Defense counsel did not join Pames’ pro se oral motion; the court nevertheless held a hearing, found the plea colloquy and counsel competent, found prejudice to the State from pleas entered mid-trial, denied withdrawal, and imposed a 40-year aggregate sentence.
- Pames appealed, arguing the trial court abused its discretion in denying his presentence motion to withdraw guilty pleas; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in denying Pames’ presentence motion to withdraw his guilty pleas | Trial court properly denied: thorough Crim.R.11 colloquy, competent counsel, motion not timely or filed, defense counsel didn’t join pro se motion, State prejudiced by mid-trial pleas | Pames claimed involuntariness: distracted by father’s cancer, pressured by father and attorneys, didn’t understand he pled to all four cases (only willing to plead rape), “yes” answers did not reflect his true state of mind | Affirmed. No abuse of discretion: record showed knowing, voluntary pleas, full hearing, no evidence of coercion or false promises, and prejudice to State; oral pro se motion not joined by counsel was properly considered and denied |
Key Cases Cited
- Xie v. Ohio, 62 Ohio St.3d 521 (establishes abuse-of-discretion review and that presentence withdrawal motions should be freely allowed but are not absolute; hearing required)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (standards for abuse of discretion review)
- Peterseim v. State, 68 Ohio App.2d 211 (sets factors and guidance for evaluating presentence plea-withdrawal requests)
- Kapper v. Ohio, 5 Ohio St.3d 36 (false promises inducing a plea can invalidate voluntariness)
- Barker v. United States, 579 F.2d 1219 (recognizes trial court discretion in post-plea withdrawal requests)