State v. Johnson

Citations

• 2023 Ohio 371

Syllabus

Pro se litigant guilty plea presentence request to withdraw plea abuse of discretion. The trial court admonished the defendant about proceeding pro se, but despite the admonishments, defendant opted to represent himself. Although presentence motions to withdraw a guilty plea should be liberally granted, there is no absolute right to withdraw a guilty plea prior to sentencing. The trial court did not abuse its discretion in denying the defendant's presentence motion to withdraw his plea. The record demonstrates that the defendant had a full and fair Crim.R. 11 hearing at which he understood the nature of the charges and possible penalties. He was given an opportunity to state his ground for withdrawal of his plea, which demonstrated only that he had a change of heart.