State v. Woody, 2014 Ohio 302

In 2005, then-juvenile Mike Woody participated in a robbery that led to an elderly woman’s injuries and subsequent death; he was later bound over to common pleas court and indicted on murder, aggravated robbery, and felonious assault counts.
Multiple psychological evaluations (defense and court examiners) found Woody had significant intellectual limitations / mild mental retardation but concluded he was capable of understanding proceedings and assisting in his defense; a juvenile court entry found him competent to stand trial.
In January 2007 Woody pled guilty to involuntary manslaughter and felonious assault and received an agreed 18-year sentence.
Woody filed a post‑sentence Crim.R. 32.1 motion to withdraw his plea claiming incompetence, medication effects, and ineffective assistance; the trial court denied it without a hearing and this court previously affirmed (first motion appeal dismissed when transcript was not filed).
In a second Crim.R. 32.1 motion Woody attached the psychiatrists’ reports, jail medication logs, and the plea transcript and argued these outside‑the‑record materials showed manifest injustice; the trial court denied the motion as barred by res judicata.
The Eighth District affirmed: the reports were available at the time of plea and could have been raised earlier; the reports actually supported competency findings; Woody did not show manifest injustice or prejudice from counsel’s failure to include the reports in the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Woody’s second Crim.R. 32.1 motion is barred by res judicata	State: second motion reasserts claims that were or could have been raised earlier, so res judicata bars it	Woody: second motion relies on outside‑the‑record documents not previously part of the record; res judicata would work an injustice because earlier motions were denied without a merits hearing	Affirmed: claims could have been raised in the first motion because the documents were available at the time of plea; res judicata applies
Whether counsel’s failure to ensure psychiatric reports were in the record amounted to ineffective assistance prejudicing Woody	State: no prejudice because reports actually support competency; counsel’s omission did not change outcome	Woody: omission denied effective assistance and prevented appellate review of competency issues	Held: No ineffective assistance — no deficient result because reports show competency and no reasonable probability of a different outcome

State v. Perry, 10 Ohio St.2d 175 (establishes res judicata principle in postconviction proceedings)
Strickland v. Washington, 466 U.S. 668 (two‑part test for ineffective assistance of counsel)
State v. Xie, 62 Ohio St.3d 521 (standard of review for postsentence plea withdrawal — abuse of discretion)
State v. Ketterer, 126 Ohio St.3d 448 (res judicata bars claims that were or could have been raised earlier)
State ex rel. Schneider v. Kreiner, 83 Ohio St.3d 203 (definition of "manifest injustice" guidance)
State v. Smith, 49 Ohio St.2d 261 (postsentence plea withdrawal is allowed only in extraordinary cases)