State v. Sanchez, 2017 Ohio 7442

Sanchez was indicted on six counts (multiple cocaine-trafficking charges, permitting drug abuse, and RICO-style corrupt activity) in August 2015.
In August 2016 Sanchez pled guilty to five counts; one count and a major-drug-specification were dismissed; court sentenced him to an aggregate 14-year prison term.
Sanchez appealed; initial direct appeal was dismissed under Anders, counsel withdrawn.
In April 2017 Sanchez filed a post‑sentence motion to withdraw his guilty plea, arguing the lab report showed only total mixture weight (including filler), so the record did not support first‑degree trafficking convictions under Gonzales.
The trial court denied the motion without an evidentiary hearing; Sanchez appealed that denial to the Third District.
The Third District affirmed, concluding that under the Ohio Supreme Court’s reconsidered Gonzales decision, total weight including fillers may be used to determine offense level, so Sanchez’s motion lacked arguable merit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post‑sentence motion to withdraw plea required a hearing or vacatur because convictions exceeded amount supported by lab report	Trial court contends motion must show facts that, if true, require withdrawal; no such showing here	Sanchez argues lab report only showed mixture weight, so convictions as first‑degree felonies were unsupported under Gonzales	Denied: no hearing required; motion lacked arguable merit under current Gonzales law recognizing total weight including fillers
Whether Sanchez was improperly sentenced for first/second‑degree felonies when evidence only supported fifth‑degree offenses	Trial court/State: applicable offense level determined by total drug weight including fillers per Gonzales (reconsidered)	Sanchez: Gonzales initially required pure-drug weight, so his plea and sentence were invalid for higher degrees	Overruled: Ohio Supreme Court’s reconsideration permits using total weight including filler; sentences stand

Anders v. California, 386 U.S. 738 (U.S. 1967) (standards for counsel withdrawing on appeal when no nonfrivolous issues exist)
State v. Hamed, 63 Ohio App.3d 5 (Ohio App. 1989) (post‑sentence plea‑withdrawal: hearing required if defendant’s allegations, accepted as true, would mandate withdrawal)
State v. Blatnik, 17 Ohio App.3d 201 (Ohio App. 1984) (same principle regarding post‑sentence motions to withdraw pleas)
State v. Nathan, 99 Ohio App.3d 722 (Ohio App. 1995) (trial court’s gatekeeping role in deciding whether to hold evidentiary hearing on plea‑withdrawal motion)