State v. Nikolic

Citations

• 2020 Ohio 3718

Syllabus

Waiver disqualify counsel invalid plea reasonable probability mandatory deportation advisement deficient prejudice. - Defendant's guilty plea waives all appealable errors unless the errors precluded him from entering a knowing, voluntary, and intelligent plea. Defendant's challenge to the trial court's implicit denial of his motion to disqualify counsel was waived and the defendant did not demonstrate the existence of a reasonable probability that he would not have pleaded guilty or that he did not enter a knowing, voluntary, or intelligent plea based on the court's denial of his motion. Trial counsel was deficient in failing to advise defendant about mandatory deportation, but defendant failed to demonstrate how he was prejudiced by the deficient performance.