State v. Quarterman
2013 Ohio 3606
Ohio Ct. App.2013Background
- Alexander Quarterman, originally charged in juvenile court for armed robbery of friends; statute required mandatory transfer to adult court for the offenses alleged.
- Grand jury indicted Quarterman in common pleas court for three counts of aggravated robbery with firearm specifications.
- Quarterman pleaded guilty pursuant to a plea agreement to one count of aggravated robbery and the firearm specification.
- Trial court sentenced him to four years in prison.
- On appeal, Quarterman raised four assignments: constitutional challenges to the mandatory juvenile-to-adult transfer provisions (due process, equal protection, Eighth Amendment) and an ineffective-assistance claim based on counsel’s failure to challenge transfer.
- The Ninth District affirmed, holding he waived those challenges by pleading guilty and did not show ineffective assistance that rendered his plea involuntary.
Issues
| Issue | Plaintiff's Argument (Quarterman) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Constitutionality of mandatory transfer (due process) | Mandatory transfer provisions in R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b) violate due process | Transfer was statutory; jurisdiction in common pleas court is proper; issue nonjurisdictional | Waived by guilty plea; not reached on merits |
| Constitutionality of mandatory transfer (equal protection) | Mandatory transfer provisions violate equal protection | No merit; statute rationally related to legislative purposes | Waived by guilty plea; not reached on merits |
| Constitutionality of mandatory transfer (cruel and unusual punishment) | Mandatory transfer violates Eighth Amendment protections | Mandatory bindover is not punishment; Eighth Amendment inapplicable | Waived by guilty plea; not reached on merits |
| Ineffective assistance for failing to challenge transfer | Counsel was ineffective for not objecting to transfer statute, which is unconstitutional | Guilty plea waived most claims; defendant did not show counsel’s performance made plea involuntary or caused prejudice | Overruled — claim waived because defendant did not argue counsel’s performance rendered plea involuntary; concurrence finds no prejudice under Strickland |
Key Cases Cited
- State v. Fitzpatrick, 102 Ohio St.3d 321 (2004) (guilty plea waives prior nonjurisdictional constitutional claims)
- Tollett v. Henderson, 411 U.S. 258 (1973) (guilty plea bars later challenges to pre-plea constitutional deprivations)
- State v. Ketterer, 111 Ohio St.3d 70 (2006) (guilty plea waives constitutional claims unrelated to plea)
- State v. Wilson, 73 Ohio St.3d 40 (1995) (common pleas court has jurisdiction over transferred juvenile cases)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-part ineffective-assistance standard)
- State v. Bradley, 42 Ohio St.3d 136 (1989) (prejudice standard for ineffective assistance)