State v. Williams, 2017 Ohio 8733

Rodney Williams pleaded guilty in two Cuyahoga County cases to an amended count of burglary and one count of drug possession; other charges were nolled.
The parties (prosecution and defense) agreed to recommend an 18-month prison term (no judicial release) as part of the plea bargain.
At the plea hearing the trial court explicitly told Williams the agreed 18-month recommendation was not binding and the court could impose more or less time; Williams acknowledged understanding.
At sentencing the prosecutor initially advocated a higher-end sentence (up to 36 months) but then corrected to acknowledge the parties’ 18‑month agreement; the court sentenced Williams to 24 months for burglary (concurrent to 12 months for possession).
Williams appealed, raising: (1) the state’s failure to honor the agreed sentencing recommendation deprived him of the plea benefit; and (2) his trial counsel was ineffective for failing to object when the state initially argued for a higher sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court breached the plea bargain by imposing 24 months instead of the agreed 18 months	State: The court is not bound by prosecutor recommendations; any agreement was presented as a recommendation	Williams: He was denied the benefit of the bargain because the court imposed a higher sentence than the agreed recommendation	The court held no breach: the trial court had warned Williams at plea that it could reject the recommendation, and the record shows the court independently explained reasons for 24 months
Whether counsel was ineffective for failing to object when the state initially recommended a higher sentence	State: Counsel acted reasonably by clarifying the agreed recommendation and advocating mitigation	Williams: Counsel’s failure to object to the prosecutor’s initial statement was deficient and prejudicial	The court held counsel was not ineffective: counsel promptly confirmed the 18‑month agreement and argued mitigation; Strickland standard not met

State v. Buchanan, 154 Ohio App.3d 250 (Ohio App. 2003) (trial court has discretion and is not bound by prosecutor recommendations)
Akron v. Ragsdale, 61 Ohio App.2d 107 (Ohio App. 1978) (court’s sentencing discretion in plea agreements)
State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (requirements for acceptance of plea agreements and notice when court may deviate)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part test for ineffective assistance of counsel)
State v. Bradley, 42 Ohio St.3d 136 (Ohio 1989) (applying Strickland in Ohio)