State v. Smith, 2014 Ohio 3855

Appellant Amanda Smith, then 17, participated in a scheme where A.L.’s 17-month-old daughter was depicted in sexual abuse photos and Smith encouraged A.L. to engage in acts and share pictures.
Appellant confessed to involvement and stated she derived sexual gratification from the images.
Juvenile court transferred the case to the general division after an amenability hearing, finding Smith not amenable to juvenile rehabilitation and that community safety required adult sanctions.
Upon transfer, the case proceeded in the general trial division, Smith pled guilty to one count of complicity to rape under a negotiated plea; the indictment was amended to remove the victim’s age, avoiding a life sentence.
Smith was sentenced to a ten-year prison term under the plea agreement, which the trial court imposed immediately after the plea.
Smith timely appealed, challenging (1) the relinquishment of jurisdiction and (2) ineffective assistance of counsel regarding the plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the juvenile court abuse its discretion in relinquishing jurisdiction?	Smith argues the court weighed factors improperly or unequally.	State contends proper consideration of R.C. 2152.12(D)-(E) supports transfer.	No abuse of discretion; factors supported transfer and time for rehabilitation was insufficient.
Did Smith receive ineffective assistance of counsel regarding the plea?	Smith asserts counsel’s performance fell below a reasonable standard impacting the plea	State argues plea was a strategic choice to avoid potential life sentence and not constitutionally deficient	No ineffective assistance; plea decision deemed a reasonable tactical choice to reduce risk of life sentence.

State v. Fontenet, 2013-Ohio-1355 (6th Dist. Lucas No. L-10-1366, 2013) (abuse of discretion standard for relinquishment of jurisdiction)
State v. Grimes, 2010-Ohio-5385 (2d Dist. Greene No. 2009-CA-30, 2010) (transfer standards; amenability analysis)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion framework)
State v. Houston, 70 Ohio App.3d 152 (6th Dist. 1990) (juvenile court not bound by experts’ opinions; considers entire record)
State v. Clayton, 62 Ohio St.2d 45 (1980) ( tactical plea decisions not per se ineffective assistance)
State v. McIntosh, 2008-Ohio-4743 (6th Dist. Erie No. E-07-048, 2008) (plea to reduce potential sentence not ineffective assistance)
State v. Jefferson, 2014-Ohio-11 (10th Dist. Franklin No. 12AP-238, 2014) (effective assistance when plea reduces risk of life sentence)
State v. Davidson, 2010-Ohio-3928 (6th Dist. Lucas No. L-09-1194, 2010) (plea reduction of sentence not ineffectiveness)