State v. Smith, 2025 Ohio 3113

Warren County grand jury indicted Martel Jayci Pate Smith on 14 counts (trafficking, possession of criminal tools, possession); Smith initially pleaded not guilty.
On January 8, 2025, Smith accepted a plea: guilty to five counts of second‑degree trafficking and two counts of third‑degree trafficking; the State dismissed the remaining seven counts.
The plea included a jointly recommended/agreed sentence of 5 to 7.5 years; the trial court accepted the plea and imposed that sentence on January 15, 2025.
Smith appealed, raising two assignments of error: (1) the record supports a lower, concurrent minimum sentence (2–3 years) based on mitigating factors; (2) trial counsel was ineffective for not negotiating a lower sentence.
The Court of Appeals held the jointly recommended sentence was authorized by law and not reviewable under R.C. 2953.08(D)(1), and rejected the ineffective‑assistance claim under Strickland.
Judgment affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence is supported by the record / reviewable	The agreed 5–7.5 year sentence is jointly recommended and authorized by law and therefore not reviewable under R.C. 2953.08(D)(1).	The record and mitigation (education, difficult childhood, no priors, undercover buys) support a lower "minimum time, concurrent" sentence (2–3 years).	Overruled. Jointly recommended sentence is authorized and not reviewable; sentence affirmed.
Whether trial counsel was ineffective for failing to negotiate a lower sentence	Counsel obtained the State’s best and final plea offer; the State has no duty to make a better offer; no deficient performance or prejudice.	Counsel should have further negotiated for a lower sentence.	Overruled. Smith failed to show deficient performance or prejudice under Strickland; no ineffective assistance.

Strickland v. Washington, 466 U.S. 668 (established the two‑prong ineffective‑assistance test: deficient performance and prejudice)