State v. Stanley, 2016 Ohio 7176

Savannah Stanley was indicted on multiple drug charges; after suppression, she pled guilty on December 10, 2015 to two counts of trafficking in cocaine (two fifth-degree felonies) pursuant to a plea agreement; remaining counts were dismissed.
At the Crim.R. 11 plea colloquy the trial court advised Stanley of rights, charge elements, maximum penalties, probation eligibility, and asked whether the plea was voluntary; Stanley affirmed understanding and voluntariness and signed the plea form.
On January 21, 2016 (pre-sentence), Stanley filed a motion to withdraw her guilty pleas, asserting she was "persuaded and influenced" into accepting the plea and did not fully understand or agree with it; she also requested new counsel.
The court held a hearing on the motion; the State opposed withdrawal, noting no new evidence, correct penalties were recited, and no claim of actual innocence.
The trial court denied the motion on February 22, 2016, finding the record (plea transcript and written plea petition) showed Stanley knowingly and voluntarily pled guilty; Stanley was later sentenced to 11 months in prison.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by denying pre-sentence motion to withdraw guilty plea	Denial appropriate: plea colloquy complied with Crim.R. 11, no new evidence, no claim of innocence, State would be prejudiced	Stanley: plea was the product of persuasion/influence; she did not fully understand or agree to it	Court: No abuse of discretion—plea was knowing and voluntary; majority of withdrawal factors favor denial

State v. Xie, 62 Ohio St.3d 521 (1992) (trial court must hold hearing and may deny pre-sentence plea withdrawal in its sound discretion)
Barker v. U.S., 579 F.2d 1219 (10th Cir. 1978) (discusses factors and discretion in plea-withdrawal decisions)
State v. Boles, 187 Ohio App.3d 345 (2010) (abuse-of-discretion framework for reviewing plea-withdrawal rulings)