State v. Williams
2017 Ohio 2650
Ohio Ct. App.2017Background
- Defendant Franklyn Williams was tried on multiple consolidated indictments charging aggravated robbery, robbery, kidnapping, theft, misuse of a credit card, weapons-under-disability, fleeing/eluding, and drug possession with various firearm and repeat-offender specifications.
- On day two of trial Williams pleaded guilty pursuant to a negotiated global 14-year sentence; multiple charges and specifications were dismissed as part of the plea.
- Williams asked the trial judge during the plea colloquy whether judicial release could be considered after seven or eight years; the judge and defense counsel made remarks suggesting the possibility of consideration at that time.
- The plea record also shows the prosecutor dismissed certain specifications (notice of prior conviction and repeat violent offender) so the parties could finalize the 14-year agreement.
- Under R.C. 2929.20(C) as applicable, because Williams had mandatory terms the earliest feasible judicial-release eligibility depended on expiration of all mandatory terms and, given his aggregated mandatory exposure, he would not be eligible until much later (effectively after serving mandatory time totaling years beyond seven/eight).
- Williams appealed, claiming his plea was not voluntary and that he received ineffective assistance; after appeal he moved to withdraw his pleas. The appellate court reversed and remanded, concluding Williams was misinformed about judicial-release eligibility and was prejudiced.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams's plea was knowing, voluntary, and intelligent given statements about judicial release | State: Trial court need not inform defendants about judicial-release eligibility under Crim.R.11 unless it is part of the plea bargain; court substantially complied with Crim.R.11 | Williams: He was told (by judge and counsel) that judicial release could be considered after 7–8 years and relied on that in pleading guilty; misstatement rendered plea unknowing and involuntary | Court reversed: erroneous information about judicial-release timing prejudiced Williams; plea not knowing, voluntary, intelligent |
| Whether the trial court substantially complied with Crim.R.11 regarding maximum penalty and effects of plea | State: Court substantially complied and informed defendant of sentence and that judicial release was not promised | Williams: Colloquy created specific expectation as to when judicial release could be sought, so Crim.R.11 protections were undermined | Court: Substantial compliance insufficient where court and counsel gave inaccurate assurance about eligibility timing; reversal required |
| Whether erroneous statements about judicial release require a showing of prejudice | State: Even if misstatement, defendant must show he would not have pled but for the error | Williams: Argued he would not have pled because trial was underway and judicial-release prospect motivated plea | Court: Found prejudice — Williams would not have pleaded but for erroneous information; plea vacated |
| Whether other assigned errors (ineffective assistance re: suppression; denial of hearing on post-sentence withdrawal) required review | State: Those issues are independent errors to be addressed if plea stands | Williams: Raised them, but they depend on plea validity | Held: Court deemed those claims moot after finding plea invalid and did not address them |
Key Cases Cited
- State v. Engle, 74 Ohio St.3d 525 (Ohio 1996) (guilty plea must be knowing, voluntary, and intelligent)
- State v. Ballard, 66 Ohio St.2d 473 (Ohio 1981) (trial court must comply with Crim.R.11 requirements)
- State v. Veney, 120 Ohio St.3d 176 (Ohio 2008) (strict compliance required for Crim.R.11 constitutional-rights warnings)
- State v. Clark, 119 Ohio St.3d 239 (Ohio 2008) (substantial compliance standard for nonconstitutional Crim.R.11 warnings)
- State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (defendant's subjective understanding controls substantial compliance analysis)
- State v. Horch, 154 Ohio App.3d 537 (Ohio Ct. App. 2003) (guilty plea invalid where defendant was misinformed about judicial-release eligibility)
- State v. Caplinger, 105 Ohio App.3d 567 (Ohio Ct. App. 1995) (finding substantial compliance where defendant appreciated plea effect despite errors)