State v. Seanunier, 2017 Ohio 852

Defendant Joseph C. Seaunier III was arrested after conveying prescription pills and other contraband into the Tri-County Jail; charged with multiple counts including illegal conveyance of drugs (third-degree felonies) and possession of marijuana (minor misdemeanor).
Indictment (March 3, 2016) charged three counts of illegal conveyance, one count possession of dangerous drugs, and one count possession of marijuana; additional illegal-conveyance count added by bill of information based on April 14 conduct.
On April 29, 2016 Seaunier waived indictment as to the new count and pleaded guilty to one count of illegal conveyance and to possession of marijuana in exchange for dismissal of four other counts and a promised presentence investigation.
Presentence report showed extensive criminal history (nineteen adult convictions over ~20 years), prior illegal-conveyance conviction, repeated smuggling of medication into jail, and a very high risk of recidivism per ORAS.
At sentencing the court imposed the maximum 36-month prison term for illegal conveyance and a six-month driver’s-license suspension; no additional jail time for the marijuana count.
Appellate counsel filed an Anders brief raising two potential issues (maximum sentence and ineffective assistance); the court conducted independent review, found no non-frivolous issues, and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether imposition of maximum sentence was erroneous	State argued sentence within statutory range and court considered R.C. 2929.11/2929.12 factors	Seaunier sought community control and treatment, asserted addiction and health issues to argue against maximum term	Affirmed — court acted within discretion, considered statutory sentencing factors and defendant's extensive criminal history justified maximum term
Whether trial counsel was ineffective in advising the plea	State contended plea was reasonable: it secured dismissal of multiple felonies and reflected facts weak for a defense	Seaunier suggested possible defenses (prescription, voluntary surrender of meds) and claimed counsel should have litigated	Affirmed — no meritorious ineffective-assistance claim; plea reasonable given record and concessions at sentencing

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for counsel seeking to withdraw when appeal is frivolous)
Penson v. Ohio, 488 U.S. 75 (U.S. 1988) (appellate courts must perform independent review when counsel files Anders brief)
State v. King, 2013-Ohio-2021 (Ohio Ct. App.) (trial court has discretion to impose any sentence within statutory range)
State v. Leopard, 194 Ohio App.3d 500 (Ohio Ct. App. 2011) (trial courts must consider sentencing statutes when exercising discretion)
State v. Mathis, 109 Ohio St.3d 54 (Ohio 2006) (requirements for sentencing court to consider statutory factors)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged ineffective-assistance test)
State v. Bradley, 42 Ohio St.3d 136 (Ohio 1989) (adoption of Strickland standard in Ohio)
State v. Cook, 65 Ohio St.3d 516 (Ohio 1992) (deference to counsel’s strategic decisions)