State v. Young, 2016 Ohio 2720

Young was charged with felonious assault (second-degree) with prior-conviction and repeat-violent-offender specifications for allegedly biting off part of a victim’s ear; plea offer reduced charge to attempted felonious assault (third-degree) with no specs.
Young cycled through appointed counsel, sought to proceed pro se, lost jail computer privileges for misuse, and was evaluated for competency (evaluators found malingering but competent).
The court repeatedly warned Young about self-representation, reappointed counsel, and produced discovery (surveillance and statement DVDs) in open court.
On the day set for trial, after discussion of risks and plea terms, Young accepted the state’s plea; the court conducted a full Crim.R. 11 colloquy and Young pleaded guilty to attempted felonious assault.
The court sentenced Young to 30 months’ imprisonment; Young appealed claiming (1) his plea was involuntary because he was effectively forced to accept counsel to obtain access to resources and witnesses, and (2) trial counsel rendered ineffective assistance (failure to locate a witness, recover seized property, and present mitigation).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of guilty plea	State: court complied with Crim.R. 11; plea was knowing and voluntary.	Young: he was forced to accept counsel and plead guilty because he was denied computer access, contact with witnesses, and recovery of seized property.	Court: plea was knowingly, intelligently, and voluntarily made; Crim.R. 11 requirements satisfied.
Ineffective assistance of counsel	State: counsel reasonably pursued defense, secured plea that reduced exposure, and made mitigation at sentencing; Young cannot show prejudice.	Young: counsel failed to locate a witness, recover potential exculpatory property, and present sufficient mitigation; these failures caused the plea.	Court: claims speculative or unsupported; no reasonable probability Young would have gone to trial but for counsel’s conduct; no prejudice shown; counsel effective.

State v. Veney, 897 N.E.2d 621 (Ohio 2008) (Crim.R. 11 strict compliance for constitutional rights; substantial compliance for nonconstitutional rights)
State v. Nero, 564 N.E.2d 474 (Ohio 1990) ("substantial compliance" means defendant subjectively understands plea implications)
State v. Stewart, 364 N.E.2d 1163 (Ohio 1977) (substantial compliance standard for nonconstitutional advisements)
Tollett v. Henderson, 411 U.S. 258 (U.S. 1973) (guilty plea waives antecedent trial rights; ineffective-assistance claims generally waived except where they affect plea voluntariness)
State v. Xie, 584 N.E.2d 715 (Ohio 1992) (standard for prejudice in plea-based ineffective-assistance claims)
Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (prejudice test for counsel’s errors in plea negotiations)
State v. Clark, 893 N.E.2d 462 (Ohio 2008) (test for showing prejudice from Crim.R. 11 partial noncompliance)