State v. Peacock, 2014 Ohio 1571

Peacock indicted Apr 19, 2012 on three counts: Trafficking in Cocaine with juvenile proximity and 5g+ amount; Trafficking in Cocaine with juvenile proximity; Possessing Criminal Tools.
Plea negotiations on Apr 11, 2013 resulted in guilty pleas to amended Count 1, Count 2, and Count 3 with a joint sentencing recommendation of nine months.
Crim.R.11 colloquy occurred; no written plea agreement.
Peacock failed to appear at the Apr 30, 2013 sentencing; bench warrant issued; resurfaced Jun 25, 2013 with new counsel appointed.
On July 11, 2013 Peacock moved to withdraw his guilty plea; August 26, 2013 court denied after a hearing with detective’s testimony and exhibits.
September 10, 2013 court sentenced Peacock to 11 months on Counts 1 and 3 and 9 months on Count 2, all concurrent; judgment entered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the motion to withdraw the guilty plea was properly denied	Peacock argues Lane factors favored withdrawal	Peacock contends his plea was involuntary duress or counsel coercion	No abuse of discretion; denial affirmed

State v. Xie, 62 Ohio St.3d 521 (1992) (post-plea withdrawal standard; requires hearing and legitimate basis)