State v. Wilson, 2014 Ohio 2342

Defendant Corey A. Wilson was indicted in Madison County on counts involving illegal use of a minor in nudity-oriented material, plus a possession charge.
He pled guilty to counts one and three; counts two, four, and five were dismissed; he received a four-year sentence on count one and a one-year sentence on count three, to run concurrently.
Wilson did not appeal his conviction or sentence directly.
He later filed a postconviction relief petition arguing ineffective assistance of counsel and suppression issues tied to statements made May 9, 2012.
The trial court denied the petition and an evidentiary hearing; the court relied on Kapper to justify denial without a hearing.
The appellate court partially reversed, finding the suppression claim required findings of fact and law or a hearing, and remanded for further proceedings on that issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying postconviction relief without a hearing on coercion claims	Wilson asserts ineffective assistance based on a guaranteed two-year sentence promise and other factors.	State contends the record shows valid Crim.R. 11 advisement and no coercive promises; no hearing required.	Partially reversed; denial without proper findings on the suppression claim.
Whether the trial court failed to make findings and conclusions on the suppression claim	Wilson argues the court did not address his claim that counsel failed to file a suppression motion for May 9, 2012 statements.	State contends the issue is subsumed by other record evidence and Miranda considerations; suppression path not properly preserved.	Remanded for findings of fact and conclusions or for an evidentiary hearing on the suppression claim.

State v. Kapper, 5 Ohio St.3d 36 (Ohio 1983) (Petition may be dismissed without a hearing when record shows no entitlement to relief)
State v. Dillingham, 2012-Ohio-5841 (12th Dist. Butler 2012) (Abuse of discretion standard; postconviction relief is collateral attack)
State v. Vore, 2013-Ohio-1490 (12th Dist. Warren 2013) (Evidentiary hearing not automatically guaranteed; significance of evidentiary facts)
State v. Blankenburg, 2012-Ohio-6175 (12th Dist. Butler 2012) (Denial of postconviction relief without hearing; substantive grounds required)
State v. McMullen, 2007-Ohio-125 (Ohio Supreme Court 2007) (Sufficiency of findings and rationale in postconviction decisions)