State v. Reynolds, 2019 Ohio 630

Reynolds pleaded guilty to six offenses (including two aggravated burglaries, robbery, felonious assault, and two burglaries) as part of an initial plea agreement that the state would recommend a 13-year prison sentence and $520 restitution.
The trial court advised Reynolds that it was not bound by the parties’ sentencing recommendation; Reynolds acknowledged this and asked for a psychiatric evaluation.
A competency evaluation found Reynolds incompetent to stand trial and he was hospitalized for restoration; his case was transferred to the mental-health docket.
After discharge, Reynolds’s counsel moved to withdraw the original plea; the mental-health court granted the motion and the prosecutor stated the 13-year recommendation was “off the table.”
Reynolds later pleaded guilty again to the same charges before the mental-health court, which imposed a 15-year prison sentence (and the previously agreed restitution). Reynolds appealed, arguing due-process violation because the state abandoned the earlier sentencing recommendation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the state breached the plea agreement by abandoning the 13-year recommendation after Reynolds withdrew his plea	State: Withdrawal of the plea relieved parties of the prior agreement; state not bound	Reynolds: He withdrew plea because incompetent; thus prior agreement should still bind sentencing and due process forbids punishment for withdrawal	Court: Reynolds was incompetent at the time of the original plea, so that plea and agreement were void; neither party was bound by it
Whether the court erred by imposing a sentence greater than the original recommendation	State: Court free to sentence de novo after plea withdrawal and competency restoration	Reynolds: Mental-health court’s greater sentence punished him for withdrawing the original plea, violating due process	Court: Trial court was not bound by a party-only plea agreement it had not adopted; it lawfully conducted de novo sentencing and did not err

Santobello v. New York, 404 U.S. 257 (1971) (plea agreements are contractual and enforceable under principles of fairness)
Parke v. Raley, 506 U.S. 20 (1992) (guilty pleas must be made knowingly, intelligently, and voluntarily)
Drope v. Missouri, 420 U.S. 162 (1975) (competency affects capacity to waive rights or plead)
State v. Engle, 74 Ohio St.3d 525 (1996) (Ohio precedent on voluntariness of pleas)
State v. Underwood, 124 Ohio St.3d 365 (2010) (trial court not bound by plea agreement between parties unless court participates or agrees)
Baker v. United States, 781 F.2d 85 (6th Cir. 1986) (discussing contractual nature of plea bargains)