State v. Rickman, 2014 Ohio 260

Rickman was indicted in case 12-CR-0086 on three counts, including Having Weapons While Under Disability, Improperly Handling Firearms, and Trafficking in Marijuana.
Rickman pleaded not guilty; counsel was appointed, and trial proceeded.
During trial, Rickman opted to plead guilty in case 0086 and separately considered pleas in cases 0235 and 0237.
On Nov. 9 and 19, 2012, Rickman attempted to withdraw or modify pleas; the court delayed and ultimately did not accept pleas in 0235 and 0237.
Rickman later moved, through new counsel, to withdraw his guilty plea in 0086 before sentencing.
The trial court denied the motion to withdraw guilty plea, and Rickman timely appealed the denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pre-sentencing withdrawal of the guilty plea was an abuse of discretion	Rickman argues the court abused its discretion	State argues the nine-factor test supports denial	No abuse of discretion; judgment affirmed

Xie v. State, 62 Ohio St.3d 521 (Ohio 1992) (establishes no absolute right to withdraw before sentencing; test is discretionary)
Francis v. State, 104 Ohio St.3d 490 (Ohio 2004) (Nine-factor test for pre-sentencing withdrawal)
State v. Maney, 2013-Ohio-2261 (Court of Appeals, 3d Dist. 2013) (totality of circumstances governs withdrawal decision)
State v. Griffin, 141 Ohio App.3d 551 (Ohio App. 7th Dist. 2001) (nonexclusive factors for withdrawal analysis)
State v. Fish, 104 Ohio App.3d 236 (Ohio App.1st Dist. 1995) (illustrates consideration of factors in withdrawal review)
State v. Liles, 2010-Ohio-5799 (Ohio App. 9th Dist. 2010) (reiterates multi-factor approach for withdrawal)
State v. Baker, 2010-Ohio-4329 (Ohio App.3d 2010) (discusses burden to show reasonable, legitimate basis)