State v. Farler

Citations

• 2026 Ohio 1070

Syllabus

Appellant's claim that his guilty pleas are invalid because the trial court failed to personally address him during the plea hearing and failed to ensure that he understood the effect of his pleas as required by Crim.R. 11(C) lacks merit because the record established that the trial court satisfied those requirements. Appellant's claim that his trial counsel was ineffective for withdrawing certain arguments from his motion to suppress lacks merit because it is purely speculative as to whether the withdrawn arguments would have been successful, and because withdrawing the arguments was a strategic and tactical decision by counsel that cannot form the basis of an ineffective assistance claim. Appellant's claim that his trial counsel provided ineffective assistance by failing to advise him to plead guilty as opposed to no contest also fails because the claim relies on evidence outside of the record and therefore cannot be raised on direct appeal. Appellant's claim that the trial court erred by imposing consecutive sentences lacks merit because the trial court made all the required consecutive-sentence findings at the sentencing hearing and in the sentencing entry, and those findings are not clearly and convincingly unsupported by the record. Appellant's claim that the trial court erred by failing to consider his present and future ability to pay financial sanctions lacks merit because no such consideration was required given that the trial court imposed only court costs, which are not financial sanctions. Judgment affirmed.