State v. Pugh, 2025 Ohio 2304

Karl E. Pugh was indicted on ten counts of pandering sexually oriented material involving a minor and ten counts of illegal use of a minor in nudity-oriented material.
Pugh entered guilty pleas to ten counts of pandering sexually oriented material involving a minor, felonies of the second degree, after extensive plea negotiations and 16 months of discovery.
After entering his pleas, Pugh moved to withdraw them, claiming he was not fully informed or was pressured due to emotional distress caused by his father's recent death.
The trial court conducted hearings on the motion to withdraw, ultimately concluding Pugh's pleas were knowingly, voluntarily, and intelligently made.
Pugh was sentenced to an indefinite prison term of two to three years and appealed, arguing his pleas were invalid and that he received ineffective assistance of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether guilty pleas were knowing, intelligent, and voluntary	Plea colloquy shows full understanding and no coercion	Pleas were entered based on erroneous advice and impaired understanding	Court found no abuse of discretion; pleas were valid
Ineffective assistance of counsel claim	Counsel’s actions did not undermine plea’s validity	Counsel failed to ensure understanding, exerted pressure, and breached confidentiality	No evidence of ineffective assistance; pleas entered knowingly and voluntarily

State v. Xie, 62 Ohio St.3d 521 (plea withdrawal standards pre-sentence)
State v. Bradley, 42 Ohio St.3d 136 (ineffective assistance of counsel standard)