State v. Scates, 2014 Ohio 418

Scates pleaded guilty to trafficking in heroin (second-degree felony) in exchange for dismissal of another charge, forfeiture, and a silent State at sentencing.
Police executed a February 23, 2012 search warrant at 315 West Pleasant Street, Springfield; heroin (12.79 grams) found in master bedroom in two baggies, a scale with residue, and a large amount of currency; no drug paraphernalia indicating abuse.
Plea colloquy occurred; court accepted the plea, found guilt, and later imposed a six-year prison term.
First assignment: ineffective assistance for not filing a suppression motion; record lacked grounds for suppression; court held no prejudice shown and the claim fails.
Second assignment: challenged six-year term under Kalish framework; court adopted Rodeffer standard under 2953.08(G)(2), found no error, and affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel’s failure to file suppression motion was ineffective	Scates argues ineffective assistance by not seeking suppression.	Scates contends suppression would have been sustained, making plea involuntary.	First assignment overruled; no prejudice shown.
Whether six-year sentence was contrary to law or an abuse of discretion	Kalish framework; sentence should be minimum due to lack of harm.	Court abused discretion by imposing longer term.	Second assignment overruled; sentence within statutory range and not an abuse of discretion.

State v. Kalish, 120 Ohio St.3d 23 (2008-Ohio-4912) (two-step felony sentencing review framework (Kalish))
State v. Rodeffer, 2013-Ohio-5759 (2d Dist. Montgomery 2013) (adopted 2953.08(G)(2) standard for appellate sentencing review)