State v. Sloan, 2022 Ohio 1930

Marcus Sloan was indicted on receiving stolen property (4th degree), improper handling of a firearm in a motor vehicle (4th degree), and obstructing justice (3rd degree).
Trooper Bransen Barr stopped Sloan after observing exaggerated/wide and other lane violations; the trial court denied Sloan’s motion to suppress following testimony and dashcam video, finding statutory violations and probable cause.
Sloan entered negotiated guilty pleas to all counts at a change-of-plea hearing; the court advised him of constitutional rights waived by a guilty plea and of maximum penalties.
At sentencing defense counsel stated that, despite the negotiated plea, they wished to pursue some appellate issues (specifically the suppression ruling).
Sloan appealed, arguing ineffective assistance because counsel allowed him to plead guilty (instead of no contest) while he intended to appeal the suppression denial; the appellate court reversed and remanded to permit withdrawal of the plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for allowing a guilty plea when appellant intended to appeal the suppression ruling	State: Plea was knowingly, intelligently, voluntarily entered and waives prior nonjurisdictional claims	Sloan: Counsel should have advised a no contest plea (which preserves appeal of pretrial rulings) given his intent to appeal suppression denial	Court: Reversed — plea was not knowingly/intelligently entered because it was premised on the mistaken belief he could still appeal; allowed withdrawal of plea
Whether counsel was ineffective at the suppression hearing for failing to object and improperly carrying burden	State: Trial record supported stop and denial of suppression; no waiver argued	Sloan: Counsel’s performance at suppression hearing was deficient	Court: Declined to address this claim as moot after reversing plea; did not rule on suppression-effectiveness claim

Strickland v. Washington, 466 U.S. 668 (establishes two-prong test for ineffective assistance of counsel)
Boykin v. Alabama, 395 U.S. 238 (guilty plea must be knowing, intelligent, and voluntary)
State v. Beasley, 152 Ohio St.3d 470 (valid counseled guilty plea generally waives prior nonjurisdictional defects)
State v. Engle, 74 Ohio St.3d 525 (plea requirements and voluntariness standards)
State v. Montgomery, 148 Ohio St.3d 347 (trial court obligation to ensure defendant understands plea consequences)
State v. Obermiller, 147 Ohio St.3d 175 (guilty plea bars later claims of prior constitutional deprivations)
State v. Petty, 134 N.E.3d 222 (interpretation supporting probable cause from wide-turn/marked-lane violation)