State v. Vales
2015 Ohio 3874
Ohio Ct. App.2015Background
- Anthony Vales was indicted in two 2014 cases: failure to notify change of address and (later) counts including rape, kidnapping, and intimidation; some charges/specifications were later nolled as part of a plea deal.
- In July 2014 Vales pleaded guilty to attempted rape, abduction (merged with attempted rape for sentencing), intimidation, and failure to notify change of address after a Crim.R. 11 colloquy with a substitute judge.
- Vales immediately—or repeatedly during pretrial proceedings—asserted he was innocent and initially rejected the plea; after a recess and a substitute judge’s colloquy he changed his plea to guilty.
- Before sentencing he timely moved to withdraw his guilty plea, claiming the plea was made under emotional pressure and that he maintained his innocence; the trial court held a hearing and denied the motion.
- At sentencing the court imposed consecutive terms totaling 14 years, imposed postrelease control, and after a separate hearing classified Vales as a sexual predator under Megan’s Law.
- Vales appealed, raising three assignments of error: denial of his presentence motion to withdraw the plea, insufficiency of evidence to classify him a sexual predator, and lack of support for consecutive sentences. The majority affirmed; one judge dissented as to plea-withdrawal.
Issues
| Issue | State's Argument | Vales' Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in denying Vales’s presentence motion to withdraw his guilty plea | The court complied with Crim.R. 11; Vales had competent counsel, received a full plea colloquy, and was afforded a hearing on the motion | Plea was emotional, made under pressure of imminent trial and risk of life sentence; he repeatedly asserted innocence and timely moved to withdraw | Denial affirmed: no abuse of discretion—Peterseim factors satisfied and record shows knowing, voluntary plea |
| Whether clear and convincing evidence supported sexual-predator classification | Violent nature of crimes, prior rape conviction (including use of a gun against a 12‑year‑old), threats and pillow used to silence victim, and extensive criminal history support likelihood to reoffend | Mitigating factors (young age at offense, no alcohol/drug use to impair victim, no multiple victims, rehabilitation/education) weigh against classification | Affirmed: totality of circumstances supports sexual‑predator label under R.C. 2950.09(B)(3) |
| Whether the record supports consecutive sentences under R.C. 2929.14(C)(4) | Consecutive sentences necessary to protect the public given extensive criminal history, prior violent sex offense, and brutality of current offense | Mitigating circumstances argue against consecutive terms | Affirmed: trial court’s findings supported; consecutive sentences appropriate |
Key Cases Cited
- State v. Xie, 62 Ohio St.3d 521 (Ohio 1992) (presentence plea‑withdrawal standard — motions should be freely and liberally granted but are within trial court discretion)
- State v. Peterseim, 68 Ohio App.2d 211 (Ohio App.) (tests/factors for evaluating presentence plea withdrawal)
- Cross v. Ledford, 161 Ohio St. 469 (Ohio) (definition and standard for clear and convincing evidence)
- State v. Schiebel, 55 Ohio St.3d 71 (Ohio) (appellate review scope for clear-and-convincing determinations)
- Boykin v. Alabama, 395 U.S. 238 (U.S.) (constitutional gravity of guilty pleas and waiver of rights)
- State v. Nero, 56 Ohio St.3d 106 (Ohio) (plea consequences and right to trial)