State v. Tyner, 2012 Ohio 2770

Tyner was indicted on felonious assault, kidnapping, and domestic violence with priors in Cuyahoga County.
He engaged in plea negotiations on the record and ultimately pleaded guilty to the indictment as charged for felonious assault and domestic violence; kidnapping plea evolved during the hearing.
Tyner initially stated innocence but later pled guilty to the kidnapping count after the court explained options.
The trial court accepted all three guilty pleas and sentenced Tyner to concurrent terms totaling four years.
Tyner challenged the plea as lacking a proper Alford inquiry and challenged counsel’s effectiveness in recommending the guilty plea.
Appellate review affirmed the trial court’s judgment and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there an Alford inquiry despite Tyner’s protestations of innocence?	Tyner insists innocence required an Alford inquiry.	Tyner argues the court should treat plea as Alford.	No Alford inquiry needed; no record of innocence on plea.
Did trial counsel’s advice render counsel ineffective regarding the plea?	Tyner claims ineffective assistance for urging plea to indictment.	Counsel’s advice was reasonable given offers and strategy.	No ineffective assistance; no reasonable probability of different outcome.

North Carolina v. Alford, 400 U.S. 25 (1970) (establishes factual basis for guilty plea despite innocence claim)
State v. Xie, 62 Ohio St.3d 521 (1992) (Strickland standard for guilty-plea ineffective assistance)
State v. McNeill, 83 Ohio St.3d 438 (1998) (burden on defendant to prove ineffective assistance)