State v. Gifford

Citations

• 179 N.E.3d 761
• 2021 Ohio 3806

Syllabus

The trial court did not abuse its discretion in failing to find a manifest injustice that would permit the defendant-appellant to withdraw his guilty plea after sentence had been imposed. The earlier offense that elevated the charge in the new case to felony-level domestic violence had been misrecorded as aggravated menacing rather than as assault, and a court speaks through its entries. But either of those offenses when committed against a family or household member elevates the degree of a later domestic violence charge. The trial court's judgmnet denying the motion to withdraw plea is affirmed.