State v. Pringle
2016 Ohio 1149
Ohio Ct. App.2016Background
- John Pringle was indicted on nine counts after firing a shotgun during a domestic dispute and at responding officers; as part of a plea bargain he pleaded guilty to domestic violence and felonious assault with a firearm specification and seven counts were dismissed.
- The trial court sentenced Pringle to a mandatory seven-year term for felonious assault plus a consecutive three-year firearm specification (aggregate ten years); 90 days for domestic violence to run concurrently.
- Five years after sentencing Pringle moved to withdraw his guilty plea, alleging ineffective assistance of counsel (failure to share discovery, lack of visits/communication, coercion into plea).
- The trial court denied the post-sentence Crim.R. 32.1 motion without an evidentiary hearing, finding the record contradicted Pringle's claims and that he entered his plea knowingly, intelligently, and voluntarily.
- Pringle appealed, arguing the trial court abused its discretion by denying withdrawal and by not holding a hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pringle established manifest injustice to withdraw a post‑sentence guilty plea | State: Trial court properly denied motion; record shows valid plea and no need for hearing | Pringle: Counsel was ineffective (didn't share discovery, failed to communicate, coerced plea), so plea was not knowing/voluntary | Affirmed: No abuse of discretion; record shows plea was knowing, voluntary, and counsel was not ineffective |
| Whether ineffective assistance of counsel supports withdrawal | State: Evidence shows counsel obtained discovery, handled competency evaluation, negotiated plea; not deficient | Pringle: Counsel's alleged neglect and coercion rendered plea unknowing | Court: Allegations contradicted by record; even persistent counsel urging is not coercion; no deficient performance shown |
| Whether the plea colloquy and written agreement were sufficient | State: Written plea and plea hearing establish understanding of charges, facts, rights, and mandatory sentence | Pringle: Lacked understanding of evidence and consequences due to counsel failures | Court: Plea colloquy, written agreement, and Pringle's affirmative answers confirm understanding |
| Whether an evidentiary hearing was required | State: No hearing required where record refutes allegations | Pringle: Requested hearing to develop factual record supporting ineffective assistance | Court: No hearing required because allegations were refuted by the record and thus insufficient to show manifest injustice |
Key Cases Cited
- Xie v. State, 62 Ohio St.3d 521 (establishes test for withdrawing plea based on ineffective assistance: deficient performance + reasonable probability defendant would not have pled)
- Strickland v. Washington, 466 U.S. 668 (Two‑part standard for ineffective assistance of counsel)
- State v. Smith, 49 Ohio St.2d 261 (delay in seeking withdrawal can affect credibility of motion)