State v. Hawkins

Citations

• 2019 Ohio 4162

Syllabus

Guilty plea Crim.R. 11(C) group-plea hearing history of mental-health issues incompetency hearing purposes of felony sentencing R.C. 2929.11 ineffective assistance of counsel. Defendant's plea was made knowingly, intelligently, and voluntarily. Where the trial judge complied with Crim.R. 11(C), a group-plea hearing did not adversely affect the validity of defendant's plea. The defendant's history of mental-health issues did not invalidate his guilty plea where the totality of the circumstances, including the discussions between the trial court and the defendant and defendant's behavior, indicated the plea was knowing and voluntary. The trial court was not required to hold a competency hearing where no party requested such a hearing and the defendant's behavior indicated he understood the nature of the proceedings and could assist with his own defense. The trial court considered the relevant sentencing factors of R.C. 2929.11 and the defendant did not demonstrate by clear and convincing evidence that the record did not support the sentence. Defense counsel did not demonstrate ineffective assistance of counsel by failing to request a competency hearing.