State v. Williams, 2020 Ohio 3802

Williams pleaded guilty pursuant to a negotiated disposition to four counts of second-degree robbery, four counts of first-degree kidnapping, and one count of receiving stolen property across three case numbers; three robbery counts carried mandatory one-year firearm specifications.
The parties jointly recommended a sentencing range of 10 to 15 years; the trial court imposed 15 years of consecutive prison terms.
Appellate counsel filed an Anders brief seeking to withdraw; Williams filed a pro se brief raising two assignments of error: (1) consecutive sentences contrary to law because the record lacks statutory findings, and (2) ineffective assistance of trial counsel.
The court examined whether a sentence imposed within a jointly recommended range is reviewable under R.C. 2953.08(D)(1) and whether counsel’s conduct met Strickland standards.
The court held the sentence was not reviewable because it was within the jointly recommended, authorized-by-law range; Williams’s challenge to consecutive findings was overruled.
The court also rejected Williams’s ineffective-assistance claim, finding counsel’s performance not deficient and no showing of prejudice (Williams faced well over 200 years exposure absent the plea).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences are contrary to law because record lacks statutory R.C. 2929.14(C)(4) findings	State: sentence was jointly recommended and authorized by law, thus not reviewable under R.C. 2953.08(D)(1)	Williams: record insufficient to support consecutive terms; due process violated	Court: Affirmed — sentence not reviewable because it was imposed within a jointly recommended, authorized range; first assignment overruled
Whether trial counsel provided ineffective assistance	State: counsel negotiated a favorable plea that substantially reduced exposure and performance was reasonable	Williams: counsel advised plea poorly, failed to investigate witnesses/alibi, and Williams received maximum of recommended range	Court: Affirmed — no deficient performance or prejudice shown; plea benefitted Williams given potential >200-year exposure; second assignment overruled

Anders v. California, 386 U.S. 738 (1971) (procedural requirements when counsel deems appeal frivolous)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance of counsel)
State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (standard for appellate review of felony sentences under R.C. 2953.08(G)(2))
State v. Grant, 111 N.E.3d 791 (Ohio 2018) (jointly recommended sentence within an authorized range is not reviewable on appeal)
State v. Bradley, 538 N.E.2d 373 (Ohio 1989) (Ohio adoption of Strickland two-prong test)
State v. Clayton, 402 N.E.2d 1189 (Ohio 1980) (trial strategy/tactics not a basis for ineffective-assistance claim)