State v. Wade, 180 N.E.3d 722

Jordyn Wade, just under 17 at the time, was convicted of multiple homicides and related offenses and sentenced to 172.5 years to life.
This court remanded for resentencing because the trial court had not explicitly considered Wade's youth as a mitigating factor per State v. Long.
At resentencing the trial court again imposed 172.5 years to life; on direct appeal this court found the trial court had complied with Long but noted limited findings regarding youth.
Wade claimed ineffective assistance of counsel at resentencing (failure to investigate/present mitigation, minimal jail visits by counsel, no mitigation expert) and filed a postconviction petition under R.C. 2953.21 to develop off‑record evidence.
The trial court denied the petition without an evidentiary hearing, concluding Wade failed to show prejudice under Strickland and that his filings lacked operative facts about what mitigation existed.
Wade appealed, arguing the denial without a hearing and the trial court's written entry were erroneous; the appellate court affirmed.

Issue	Wade's Argument	State's Argument	Held
Whether Wade was entitled to an evidentiary hearing on his postconviction petition alleging ineffective assistance at resentencing	Counsel failed to investigate or present mitigation (few visits, no mitigation expert, counsel admitted not reading remand opinion); these facts warrant a hearing to develop off‑record evidence	Wade did not proffer operative facts or affidavits showing what mitigating evidence existed or that its presentation would likely change the outcome (prejudice under Strickland)	No hearing required; petitioner failed to show prejudice under Strickland and did not proffer sufficient operative facts to require an evidentiary hearing
Whether the trial court's denial complied with R.C. 2953.21(H) (findings of fact and conclusions of law)	The trial court's entry was too cursory and did not explain why Wade failed to set forth operative facts	The court's decision addressed the evidence, stated the governing standards, and explained denial on prejudice grounds; labeling is not required if findings are comprehensive	The entry was adequate: findings and legal reasoning were sufficient for review and compliance with the statute

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective assistance standard)
State v. Long, 138 Ohio St.3d 478 (requires sentencing courts to consider youth as a mitigating factor)
State v. Calhoun, 86 Ohio St.3d 279 (postconviction relief is a collateral attack; hearing not automatic)
State v. Jackson, 64 Ohio St.2d 107 (petitioner must submit evidentiary documents with operative facts to obtain a hearing)
State v. Cole, 2 Ohio St.3d 112 (to secure a hearing petitioner must proffer evidence that, if believed, establishes deficient counsel and prejudice)
State v. Keith, 79 Ohio St.3d 514 (to prove prejudice from failing to present mitigation, petitioner must show existence of mitigating evidence and reasonable probability of different outcome)
State v. Milanovich, 42 Ohio St.2d 46 (older standard recognizing that some postconviction claims depend on off‑record facts)