State v. Reinhardt, 2014 Ohio 4071

Reinhardt was indicted in May 2012 for four counts of deception to obtain a dangerous drug (hydrocodone and diazepam), felonies of the fifth degree.
She entered a written plea agreement before trial, pleading guilty to one misdemeanor theft in exchange for dismissal of the four felony counts and a related indictment.
Trial court accepted the guilty plea after a Crim.R. 11 colloquy and sentenced Reinhardt to three years of community control with 12 months electronic monitoring.
In August 2013, Reinhardt moved under Crim.R. 32.1 to withdraw her plea, supported by affidavits alleging coercion and judicial bias.
She claimed her attorney pressured her due to perceived judge anger, and she feared jail after trial; she also asserted bias shown by the trial judge and post-plea statements.
The trial court denied the motion, finding no manifest injustice and noting its participation in the process; Reinhardt appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the post-sentence Crim.R. 32.1 motion showed manifest injustice	Reinhardt (plaintiff) argues coercion by counsel and judge bias induced plea	Reinhardt (defendant) contends coercive conduct violated voluntariness	No manifest injustice; denial affirmed
Whether counsel’s conduct constituted ineffective assistance to withdraw plea	Reinhardt claims deficient performance coerced plea	Counsel’s conduct fell within reasonable trial strategy	Not deficient; strategy reasonable
Whether the trial court’s participation in plea negotiations biased the proceedings	Trial court biased against Reinhardt influenced plea	Record does not show improper coercion by judge	No substantial coercion by judge; no manifest injustice
Whether the court-promised sentence induced the plea and its breach invalidated it	Promised no jail time induced plea; breach invalidates	Sentence actually imposed did not include jail time due to circumstances	Promise not binding given sentencing outcome did not include jail time
Whether postplea statements and codefendant sentencing affected voluntariness	Postplea events show coercion	Postplea remarks did not cause involuntary plea	Not enough to establish involuntariness

State v. Shirley, 2013-Ohio-5216 (1st Dist. Hamilton No. C-130121 (Ohio Ct. App. 2013)) (manifest injustice standard for Crim.R. 32.1 post-sentence withdrawals)
State v. Smith, 49 Ohio St.2d 261 ((1977)) (syllabus on manifest injustice in plea withdrawals)
State v. Kostyuchenko, 8 N.E.3d 353 (2014-Ohio-324) (abuse-of-discretion review for manifest injustice)
State v. Dye, 2013-Ohio-1626 (1st Dist. Hamilton No. C-120483) (no hearing required if no merit to withdrawal)
State v. Holloman, 772 N.E.2d 119 ((Ohio 2002)) (ineffective assistance standard under Strickland)
State v. Byrd, 407 N.E.2d 1384 ((Ohio 1980)) (judge's participation in plea bargaining can coerce)
State v. Pippin, 915 N.E.2d 715 ((Ohio App. 1st Dist. 2009)) (judge involvement in plea bargaining)
State v. Sawyer, 915 N.E.2d 715 ((Ohio App. 1st Dist. 2009)) (additional analysis on coercion and voluntariness)
Bonnell, 2002-Ohio-5882 ((12th Dist. 2002)) (promised sentence as inducement to plea; breach voids voluntariness)