State v. Taylor, 2017 Ohio 4395

On June 5, 2015, an Ohio State Highway Patrol trooper stopped Aaron M. Taylor, observed marijuana, and later found heroin in the vehicle and on Taylor.
A grand jury indicted Taylor for possession of heroin (R.C. 2925.11(A)); he pleaded not guilty and the case was set for jury trial.
On the morning trial began Taylor sought to plead guilty; the trial court refused, citing a court policy against last‑minute pleas, but excluded certain "late" videotape evidence the defense complained about.
A jury convicted Taylor; at sentencing the judge considered Taylor's criminal history, substance‑abuse issues, and the excluded videotape (mentioned by the court as showing Taylor using heroin in a police cruiser).
The trial court imposed community control (four years), community service, fines, 160 days jail, and a three‑year license suspension; Taylor appealed alleging (1) the court erred by refusing his guilty plea and (2) the sentence was vindictive/contrary to law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by refusing to accept Taylor's day‑of‑trial guilty plea	Trial court properly exercised discretion to refuse late pleas and prevent juror inconvenience	Taylor argued the court applied a blanket policy and failed to exercise discretion, disadvantaging his ability to decide given late disclosure of evidence	Court: Trial court abused discretion by applying a policy, but error was harmless because outcome (guilt) would have been the same and no prejudice shown
Whether the sentence was contrary to law because it was harsher as punishment for choosing trial (vindictive sentencing)	Sentence was lawful and based on legitimate factors (history, substance abuse, statutory limits); judge was stern but not vindictive	Taylor argued the sentence punished him for not pleading earlier and thus was vindictive/contrary to law	Court: No clear and convincing evidence of actual vindictiveness; sentence affirmed under deferential R.C. 2953.08(G)(2) review

North Carolina v. Alford, 400 U.S. 25 (1970) (no constitutional right to plead guilty)
State v. Kirkland, 140 Ohio St.3d 73, 15 N.E.3d 818 (2014) (definition of abuse of discretion)
Cross v. Ledford, 161 Ohio St. 469, 120 N.E.2d 118 (1954) (definition of clear and convincing evidence)
State v. Marcum, 146 Ohio St.3d 516, 59 N.E.3d 1231 (2016) (standard for appellate review of felony sentences under R.C. 2953.08)
State v. Rahab, 150 Ohio St.3d 152, 80 N.E.3d 431 (2017) (vindictive sentencing is contrary to law)
Bordenkircher v. Hayes, 434 U.S. 357 (1978) (punishing exercise of lawful procedural rights violates due process)
State v. Jackson, 68 Ohio App.2d 35, 426 N.E.2d 528 (no constitutional right to plead guilty)