State v. Scheaffer

Citations

• 2026 Ohio 114

Syllabus

CRIM.R. 32.1 – POSTSENTENCE MOTION TO WITHDRAW GUILTY PLEA – RES JUDICATA: The common pleas court did not abuse its discretion in denying defendant's postsentence motion to withdraw his guilty pleas under Crim.R. 32.1 without a hearing. Because defendant's challenge raised issues that could have been raised on direct appeal and was not based on evidence outside of the record, res judicata applied. Judgment affirmed.