State v. Purnell, 2018 Ohio 1036

Michael R. Purnell was indicted on two robbery counts (one second-degree with a repeat-violent-offender specification, one third-degree); he initially pled not guilty.
On November 28, 2016, after plea negotiations, Purnell accepted a plea to the second-degree robbery count with a joint recommended sentence of four years; the court conducted a full Crim.R. 11 colloquy and accepted the plea.
Before sentencing, the court modified bond conditions to allow limited house arrest; those arrangements later "fell through," and bond reverted to higher conditions.
Purnell moved (orally then in writing) to withdraw his guilty plea before sentencing, arguing: change of heart, he entered the plea against his better judgment, anticipated house arrest did not occur, and he had defenses to the charges.
The trial court held a full hearing on January 18, 2017, denied the motion to withdraw in a written entry, and then sentenced Purnell to the agreed four-year term; Purnell appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying a pre-sentence motion to withdraw a guilty plea	State: trial court properly denied motion after weighing factors and finding no reasonable/legitimate basis	Purnell: plea was entered against his better judgment; house arrest fell through; he has possible defenses and is therefore entitled to withdraw	Court: No abuse of discretion; majority of balancing factors weigh against withdrawal

State v. Xie, 62 Ohio St.3d 521 (Ohio 1992) (pre-sentence withdrawals require a reasonable and legitimate basis; motions should be liberally allowed but not automatic)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse of discretion standard defined as unreasonable, arbitrary, or unconscionable)
State v. Fish, 104 Ohio App.3d 236 (Ohio Ct. App. 1995) (lists non-exhaustive factors for evaluating pre-sentence withdrawal motions)