State v. Redd, 2015 Ohio 3164

Arlondo Redd and Kayin Pooler were charged with aggravated robbery with a deadly weapon; Redd moved to suppress statements he made to police, alleging coerced custodial interrogation and an invalid Miranda waiver.
Detective Douglas Baker testified he read a Miranda form to Redd, had Redd initial and sign it, and that Redd admitted being at the scene (but said Pooler had the gun); Redd testified his statements were false and the product of coercion.
The trial court denied the suppression motion, finding Baker more credible and concluding Redd knowingly and voluntarily waived Miranda rights based on the signed waiver form and testimony.
Redd entered a no-contest plea to a bill of information charging complicity to commit aggravated robbery (a plea deal that dismissed the indictment and a firearm specification); the court sentenced him to three years’ imprisonment.
On appeal Redd raised two assignments of error: (1) ineffective assistance of counsel for failing to object at the suppression hearing; and (2) that his no-contest plea was not knowingly and voluntarily made.
The appellate court corrected a clerical error in the trial court’s entry (it initially misstated the plea as guilty) and affirmed the conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defense counsel was ineffective for not objecting to the state’s cross-examination at the suppression hearing	State: cross-examination was proper and relevant to voluntariness; counsel’s failure to object was not deficient	Redd: state’s cross-examination exceeded scope of direct; counsel should have objected	Court: No ineffective assistance — cross-examiner’s questions were relevant and admissible at suppression hearings, so no deficient performance
Whether Redd’s no-contest plea was knowing and voluntary	State: trial court complied with Crim.R. 11(C) and addressed Redd personally; he demonstrated understanding after questioning	Redd: numerous questions and post-plea claims of innocence show he lacked understanding and voluntariness	Court: Plea was knowingly and voluntarily entered; questions indicated understanding; post-plea assertions of innocence do not vitiate voluntariness

Strickland v. Washington, 466 U.S. 668 (establishes the two-prong standard for ineffective assistance of counsel)
United States v. Matlock, 415 U.S. 164 (evidentiary rules do not apply with full force at admissibility/suppression hearings)
State v. Edwards, 107 Ohio St.3d 169 (2005) (Ohio rule that rules of evidence generally do not bind admissibility determinations in suppression hearings)
State v. Treesh, 90 Ohio St.3d 460 (Ohio permits cross-examination on matters pertinent to the case beyond direct-examination scope)
State v. Perez, 124 Ohio St.3d 122 (2009) (Evid.R. 611(B) allows cross-examination on all relevant matters)