State v. Smalley, 2019 Ohio 1572

Wesley Smalley was indicted for one count of cruelty to a companion animal (R.C. 959.131(C)).
Bench trial was held; Smalley was found guilty.
Sentencing: two years community control and 14 days in jail (7 days work release; 7 days GPS/house arrest).
Smalley appealed claiming ineffective assistance of counsel, arguing counsel failed to make any record of plea negotiations or communicate a plea offer.
The trial court reviewed the claim under the two-prong Strickland standard (deficient performance and prejudice).
The court found no evidence in the record that any plea offer or plea negotiations occurred and held Smalley’s claim was speculative, overruling the assignment of error and affirming the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to record/communicate plea negotiations	No plea offer was made; prosecution represented only an offer to plead to the indictment as charged	Counsel failed to preserve or communicate plea negotiations/offers, causing prejudice to Smalley	Claim speculative; no record evidence of any plea offer or negotiations; no deficient performance shown; conviction affirmed

Strickland v. Washington, 466 U.S. 668 (1984) (sets the two-pronged ineffective-assistance standard: deficient performance and prejudice)