State v. Williams
2016 Ohio 7782
| Ohio Ct. App. | 2016Background
- Antoine Williams was indicted on four drug- and criminal-tool–related felony counts, including illegal conveyance of drugs into a detention facility, drug trafficking, drug possession, and possessing criminal tools.
- Williams moved 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, but the trial judge stated a blanket policy of not accepting no-contest pleas and required a guilty plea instead.
- Williams agreed to plead guilty conditionally to preserve his right to appeal the denial of the suppression motion; the court accepted the guilty plea and later sentenced him to nine months concurrent on all counts.
- On appeal, Williams raised (1) that the suppression denial (and the trial court’s Crim.R. 12(F) findings) was erroneous and (2) that the trial court improperly refused to accept his no-contest plea.
- The appellate court found the trial court abused its discretion by rejecting a no-contest plea based on a blanket policy, vacated Williams’s guilty plea, and remanded for a new plea hearing; it held the suppression assignment premature.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of motion to suppress should be upheld | State: suppression denial was proper (court record supports search/seizure ruling) | Williams: Fourth Amendment violation; suppression should be granted | Not decided on merits — appellate court found this assignment premature given disposition on plea issue |
| Whether trial court erred by refusing to accept a no-contest plea based on a blanket policy | State: trial court has discretion to accept/reject no-contest pleas | Williams: court abused discretion by applying a blanket policy rather than evaluating facts/circumstances | Reversed: court abused discretion; vacated guilty plea and remanded for new plea hearing where court must consider case-specific facts before accepting a no-contest plea |
Key Cases Cited
- State v. Mehozonek, 8 Ohio App.3d 271 (8th Dist. 1983) (discusses appellate review of trial court’s exercise of discretion over pleas)
- State v. Fitzgerald, 188 Ohio App.3d 701 (8th Dist. 2010) (rejecting blanket policies; trial court must exercise discretion case-by-case when accepting/rejecting pleas)
- State v. Carter, 124 Ohio App.3d 423 (2d Dist. 1997) (trial court’s blanket refusal to accept no-contest pleas is an abuse of discretion)
- Billington v. Cotner, 32 Ohio App.2d 277 (Ohio Ct. App. 1972) (appellate oversight ensures trial judges exercise, rather than wholly refrain from, discretion)