State v. Williams
2016 Ohio 4905
Ohio Ct. App.2016Background
- Appellant Shaquille Williams pleaded guilty in consolidated Lucas County cases: (1) failure to comply with a police order (third-degree felony) and (2) two counts reduced to robbery with firearm specification and one count of participating in a criminal gang (lesser/negotiated counts).
- Plea offer was negotiated shortly before trial; prosecution threatened an additional aggravated-robbery indictment based on a co-defendant’s DVD statement (but the same co-defendant gave a written exculpatory statement).
- Williams consulted counsel during a nearly two-hour recess and entered guilty pleas after a full Crim.R. 11 colloquy; he stated the pleas were voluntary and admitted culpability.
- Two days later Williams sought to withdraw his pleas before sentencing, claiming confusion, coercion from threat of extra charges, and asserted defenses; he later filed a written motion and sought retained counsel but failed to obtain one.
- Trial court denied the pre-sentence motions to withdraw and imposed consecutive terms (one-year first-case term to run first; in the second case consecutive 18-month and 4-year terms, with overall consecutive sentencing totaling a jointly-recommended maximum of 17 years with three years mandatory).
- On appeal Williams challenged (1) denial of his pre-sentence motion to withdraw guilty pleas and (2) the statutory findings supporting consecutive sentences.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Whether trial court abused discretion by denying pre-sentence motion to withdraw guilty pleas | Trial court properly evaluated factors (prejudice to state, adequate representation, thorough Crim.R. 11 colloquy, timing) and denial was warranted | Williams claimed confusion/overwhelm, coercion by threatened additional charges, insufficient counsel and need for investigation | Affirmed — no abuse of discretion; plea was knowing/voluntary, motion untimely in practical terms, and state would be prejudiced |
| Whether record supports consecutive sentences under R.C. 2929.14(C)(4) | Consecutive terms necessary to punish, protect public, not disproportionate; gang-related conduct made harm "great or unusual" and defendant’s criminal history justified consecutive terms | Williams argued no great/unusual harm (no gun on him, no physical injury, no property damage) and consecutive terms unnecessary | Affirmed — statutory findings supported by record (gang involvement, witness intimidation, prior gang-related juvenile aggravated robbery) |
Key Cases Cited
- State v. Xie, 62 Ohio St.3d 521 (sets standard for pre-sentence withdrawal of guilty plea and trial-court discretion)
- State v. Adams, 62 Ohio St.2d 151 (abuse-of-discretion standard defined)
- State v. Bonnell, 140 Ohio St.3d 209 (trial court not required to state detailed findings on the record when imposing consecutive sentences)
- Cross v. Ledford, 161 Ohio St. 469 (definition of clear and convincing evidence)
- State v. Murphy, 176 Ohio App.3d 345 (nonexhaustive list of factors appellate courts consider when reviewing pre-sentence withdrawal motions)
- State v. Belew, 140 Ohio St.3d 221 (framework for appellate review of felony sentencing under R.C. 2953.08)