State v. Wright
2013 Ohio 936
Ohio Ct. App.2013Background
- Wright was indicted in 2007 on four counts of unlawful sexual conduct with a minor and one count of rape; a capias was issued and he was arrested in March 2008.
- Following arraignment Wright pleaded not guilty and counsel was appointed; after pretrials, trial occurred in February 2009 with guilty verdicts on all counts.
- In March 2009 Wright received a 25-year prison term and appealed; on remand, the case was narrowed to a single rape count under a modified charge.
- In 2012, after remand and a plea agreement, Wright pled guilty to an amended charge of gross sexual imposition (fourth-degree felony) and received an 18-month sentence, with credit for time served.
- The issues on appeal were (1) ineffective assistance of counsel during plea/sentencing and (2) defect in the amended indictment due to incorrect dates; the court affirmed Wright’s conviction.
- The court applied Strickland v. Washington and related Ohio standards, concluding Wright’s plea was knowing and voluntary and that the indictment defect did not affect the validity of the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel at plea/sentencing | Wright argues counsel was deficient and prejudiced | N/A in opinion beyond Wright's claim | No ineffective assistance; plea knowingly voluntary; no reasonable probability of different outcome |
| Defect in amended indictment due to incorrect dates | Amended charge incorrectly dated | N/A in opinion beyond Wright's claim | Waived by guilty plea; date error does not affect validity of conviction |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes deficient performance and prejudice standard; highly deferential review)
- State v. Bradley, 42 Ohio St.3d 136 (1989) (preserves ineffective assistance standards in Ohio)
- Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for guilty pleas)
- State v. King, 184 Ohio App.3d 226 (2009) (waiver of appeal rights when pleading guilty; knowing and voluntary plea)
- State v. Minite, 8th Dist. No. 95699, 2011-Ohio-3585 (2011) (reasonable probability standard for trial decision after guilty plea)
- State v. Ramsey, 3d Dist. No. 9-10-55, 2012-Ohio-134 (2012) (knowing, intelligent, voluntary plea waives nonjurisdictional issues)
- Stacy v. Van Coren, 18 Ohio St.2d 188 (1969) (plea waiver principles and standards)
- Tollett v. Henderson, 411 U.S. 258 (1973) (plea of guilty generally bars claims about prior proceedings)