State v. Schramm

Citations

• 2022 Ohio 1535

Syllabus

Recommendation that defendant plead guilty to second degree pandering—which prohibits the reproduction of child pornography—was not ineffective assistance of counsel where defendant admitted that he \downloaded\ child pornography from the internet onto his phone. Because the process of downloading requires taking active steps to create a copy of the image, defendant was properly charged with second degree pandering, and it was not deficient performance to advise defendant to plead guilty.