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State v. Williams
2014 Ohio 3415
Ohio Ct. App.
2014
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Background

  • Williams was charged with multiple counts of pandering sexually oriented material involving a minor, illegal use of a minor in nudity material, and possessing criminal tools; all counts included forfeiture specifications.
  • He pleaded guilty to five counts of pandering sexually oriented material involving a minor and one count of possessing criminal tools, with remaining counts nolled.
  • Sentencing judge imposed seven-year prison terms on each pandering count and a twelve-month term for tools, all concurrent, plus five years postrelease control.
  • Williams was designated a Tier II sex offender and ordered to forfeit a scandisk and a computer.
  • This appeal challenges the sentence as unlawful, and claims the guilty plea was not knowingly and intelligently entered due to ineffective assistance of counsel.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the sentence is contrary to law. Williams argues the sentences exceed statutory limits or fail to serve sentencing purposes. State contends the court properly considered sentencing guidelines and inside statutory range. No; sentences within statutory range and supported by the record.
Whether the guilty plea was knowingly, voluntarily, and intelligently entered due to ineffective assistance of counsel. Williams claims counsel's inexperience with computers and failure to review images undermined knowingness of plea. State contends counsel used a computer-forensic examiner and did not need to personally view images; plea was voluntary. No; counsel's performance not deficient; plea knowingly, voluntarily, and intelligently entered.

Key Cases Cited

  • State v. Xie, 62 Ohio St.3d 521 (1992) (standard for ineffective assistance affecting a guilty plea)
  • Hill v. Lockhart, 474 U.S. 52 (1985) (reasonable probability standard for plea withdrawal and ineffective assistance)
  • Spates, 64 Ohio St.3d 269 (1992) (defendant must show deficient performance caused guilty plea to be involuntary)
Read the full case

Case Details

Case Name: State v. Williams
Court Name: Ohio Court of Appeals
Date Published: Aug 7, 2014
Citation: 2014 Ohio 3415
Docket Number: 100459
Court Abbreviation: Ohio Ct. App.