State v. Robinson, 2015 Ohio 4262

Jacky Robinson pleaded guilty and was convicted in 2005 of aggravated murder and aggravated burglary (with firearm specs) for the death of Dennis Ober; he had earlier pleaded guilty to another murder (Grover Jones) in 2003.
Robinson confessed to Ober’s murder during police interrogation while already incarcerated for the earlier murder.
On September 30, 2014 Robinson moved post-sentence under Crim.R. 32.1 to withdraw his 2005 guilty plea, attaching (1) an affidavit and letter from Demian Duncan claiming Duncan committed both murders, and (2) Robinson’s own affidavit asserting his confessions were false and coerced to help his girlfriend.
The trial court denied the motion without an evidentiary hearing, stating it gave no weight to Duncan’s letter and (incorrectly) finding Robinson offered no other evidentiary materials; the court also held the motion was barred by res judicata.
Robinson appealed; the Ninth District reversed, holding the trial court abused its discretion by failing to address the affidavits and erred in applying res judicata, and remanded for further consideration.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Robinson)	Held
Whether trial court abused discretion by denying post-sentence motion to withdraw plea without addressing offered affidavits	The court found Duncan’s letter had no weight and (implicitly) that defendant failed to provide sufficient evidentiary support	Robinson argued he submitted Duncan’s affidavit and his own affidavit showing newly discovered evidence and coercion, which the trial court failed to consider	Reversed: trial court abused discretion by not considering Duncan’s affidavit and Robinson’s affidavit and must reconsider the motion
Whether res judicata bars the Crim.R. 32.1 motion	Trial court ruled res judicata barred relief	Robinson argued the claim rests on newly discovered evidence not available at the time of the conviction, so res judicata does not apply	Reversed: res judicata inapplicable because claim is based on new evidence not previously raised

State v. Smith, 49 Ohio St.2d 261 (establishes burden to show manifest injustice for post‑sentence plea withdrawal)
State v. Xie, 62 Ohio St.3d 521 (pre‑sentence motions to withdraw plea are freely granted; distinguishes pre‑ and post‑sentence standards)
State v. Francis, 104 Ohio St.3d 490 (clarifies trial court discretion scope when ruling on plea‑withdrawal motions)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (defines abuse of discretion standard)
Pons v. Ohio State Med. Bd., 66 Ohio St.3d 619 (appellate courts may not substitute their judgment for trial court under abuse‑of‑discretion review)
State v. Ketterer, 126 Ohio St.3d 448 (res judicata bars claims that were or could have been raised on direct appeal)
State v. Perry, 10 Ohio St.2d 175 (foundational Ohio precedent on collateral‑attack preclusion)