State v. Reynolds, 2024 Ohio 1956

Trece Reynolds was indicted on multiple felony drug offenses, including engaging in a pattern of corrupt activity, trafficking, and possession of methamphetamine and fentanyl, with major drug offender specifications.
Reynolds entered into a negotiated plea agreement: he pleaded guilty to some charges, while others (and their specifications) were dismissed or reduced.
Prior to sentencing, Reynolds absconded for almost two years and was charged with new felonies involving firearms in other counties.
At sentencing, the trial court imposed a total sentence of 14 years (11 years mandatory), with an indefinite sentence of up to 19.5 years, after finding all statutory requirements for consecutive sentencing.
Reynolds's appellate counsel filed an Anders brief, asserting the appeal was frivolous and seeking permission to withdraw; Reynolds did not file a pro se brief.
The case is on appeal from Muskingum County Court of Common Pleas, with the appellate court reviewing both the plea and sentencing for error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Guilty Plea under Crim.R. 11	Plea was knowing, intelligent, voluntary, and in compliance with Rule 11.	No non-frivolous argument offered (Anders brief).	Court found the plea valid—no meritorious issue.
Lawfulness of Consecutive Sentences	Trial court met all statutory findings for consecutive sentences.	No non-frivolous argument offered (Anders brief).	Consecutive sentences affirmed—findings supported by record.
Existence of Any Arguably Meritorious Issues for Appeal	None exist; appeal is wholly frivolous under Anders.	No pro se arguments raised.	Appeal is frivolous; counsel's withdrawal granted.
Compliance with Anders Procedures	Appellate counsel complied fully, giving Reynolds notice and opportunity to file a pro se brief.	No contrary argument presented.	Appellate procedure satisfied; withdrawal proper.

Anders v. California, 386 U.S. 738 (1967) (established procedure for counsel to withdraw on a frivolous appeal and court’s duty to independently review record)
North Carolina v. Butler, 441 U.S. 369 (1979) (written waiver form is strong evidence of valid waiver)
State v. Ballard, 66 Ohio St.2d 473 (1981) (substantial compliance standard for Crim.R. 11 non-constitutional advisements)
State v. Stewart, 51 Ohio St.2d 86 (1977) (requirements for knowing, intelligent, and voluntary plea)
State v. Nero, 56 Ohio St.3d 106 (1990) (substantial compliance under Crim.R. 11)
State v. Clark, 38 Ohio St.3d 252 (1988) (written waiver form evidence)
State v. Bonnell, 2014-Ohio-3177 (requirement for trial court to make findings for consecutive sentences)
State v. Veney, 2008-Ohio-5200 (failure to strictly comply with constitutional advisements under Crim.R. 11 renders plea invalid)