Cleveland v. Toth

Citations

• 2023 Ohio 315

Syllabus

Disorderly conduct minor misdemeanor App.R. 16 Crim.R. 11(E) no-contest plea R.C. 2937.07 ineffective assistance of counsel trial strategy double jeopardy Crim.R. 32(C) App.R. 12. Judgment affirmed. The trial court did not err in accepting the defendant's no-contest plea. The trial court properly advised the defendant pursuant to Crim.R. 11 and the record reveals that after such advisement, defendant voluntarily entered the no-contest plea. The defendant did not receive ineffective assistance of counsel where all of counsel's conduct that defendant took issue with fell into the category of trial strategy that fell within the range of reasonable professional assistance. The defendant's double jeopardy protections were not violated where the trial court's initial finding of \not guilty\ was not reduced to writing and journalized. Finally, defendant's failure to fully brief a proper substantive due process argument allowed this court to disregard it pursuant to App.R. 12(A).