State v. Williams, 2014 Ohio 3589

State v. Williams, 2014-Ohio-3589, Eighth Appellate District, affirmed Williams's conviction and vacated solitary confinement portion on direct appeal.
Williams pleaded guilty in 2006 to amended counts including involuntary manslaughter, kidnapping, aggravated robbery, and tampering with evidence.
Direct appeal affirmed nearly all convictions but vacated the solitary-confinement order; Supreme Court denied review.
In 2013 Williams, pro se, moved to vacate sentence, judgment, and conviction claiming lack of subject-matter jurisdiction and ineffective assistance of counsel.
Trial court appointed counsel and later denied the motion, finding any jurisdiction issue waived by guilty plea; Williams appeals that ruling.
Court held the postconviction relief motion was time-barred and res judicata, and affirmed denial of relief

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the postconviction relief motion was timely and authorized given waivers and prior claims	Williams argues the court erred by denying without hearing, asserting lack of jurisdiction and new rights	Williams contends the plea did not waive jurisdiction or entitlement to relief	Denied; time-bar and res judicata upheld; no hearing warranted
Whether Lafler v. Cooper creates a retroactive right to effective assistance at pleading stage	Williams asserts Lafler recognized a new retroactive right to effective counsel at plea	State argues Lafler does not create a new right at pleading stage and claims were res judicata	Denied; Lafler not a new right and claims barred by res judicata

Lafler v. Cooper, 566 U.S. 1 (U.S. 2012) (right to effective assistance applies to pretrial stages within the whole proceeding; not a new pleading-stage right)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (established standard for ineffective assistance of counsel)
State v. Jackson, 2014-Ohio-927 (8th Dist. Cuyahoga 2014) (postconviction relief timing and requirements; cited for rule about filing after direct appeal)