State v. Williams
2016 Ohio 7782
Ohio Ct. App.2016Background
- Antoine D. Williams was indicted on four felony counts related to drugs and possessing criminal tools, with various specifications.
- Williams filed a pretrial motion to suppress evidence on Fourth Amendment grounds; the trial court denied the motion after a hearing.
- Defense and prosecution reached a plea agreement; Williams sought to plead no contest to the indictment.
- The trial judge refused to accept a no-contest plea as a matter of court policy and required Williams to plead guilty instead; Williams conditioned his guilty plea on reserving the right to appeal the suppression denial. The court accepted the guilty plea with that reservation.
- Williams was sentenced to concurrent nine-month terms. He appealed, arguing (1) the suppression denial was improper and (2) the trial court erred in refusing to accept his no-contest plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly refused a no-contest plea based on a blanket policy | State argued court may accept or reject pleas and the guilty plea was valid | Williams argued the court abused discretion by applying a blanket policy refusing no-contest pleas rather than considering case-specific facts | Court held the refusal was an abuse of discretion because the court relied on a blanket policy; vacated the guilty plea and remanded for a new plea hearing |
| Whether disposition of the suppression-motion claim should be reviewed now given plea posture | State proceeded after plea; argued plea preserved appeal of suppression denial | Williams sought no-contest to preserve appellate rights; after vacatur, suppression issue deemed premature on record | Court found the suppression-assignment premature in light of vacated plea and remand |
Key Cases Cited
- State v. Mehozonek, 8 Ohio App.3d 271 (8th Dist.) (standard that trial-court plea decisions reviewed for abuse of discretion)
- State v. Fitzgerald, 188 Ohio App.3d 701 (8th Dist.) (trial court may not reject pleas based on a blanket policy; must consider facts and circumstances)
- State v. Carter, 124 Ohio App.3d 423 (2d Dist.) (blanket policy refusing no-contest pleas is an abuse of discretion)
- Billington v. Cotner, 32 Ohio App.2d 277 (discretion must be exercised and is reviewable on appeal)