State v. Singleton

Citations

• 2021 Ohio 4271

Syllabus

COUNSEL – PLEA – COMPETENCY – SENTENCE – POSTRELEASE CONTROL: The trial court did not err in declining to appoint new defense counsel where defendant withdrew his motion to appoint new counsel. The trial court did not err in finding defendant competent to stand trial where he was found to be competent by two doctors in separate evaluations, and there is no evidence in the record that defendant did not understand the nature and objective of the proceedings or that he was unable to assist in his defense. The trial court properly informed defendant at the sentencing hearing and in the sentencing entry that he was subject to mandatory postrelease control, and therefore, defendant's sentences were not void. The trial court conflated the concepts of postrelease control and parole and made contradictory statements regarding the mandatory nature of postrelease control during the plea hearing, but defendant failed to demonstrate that his pleas were not made knowingly, voluntarily, and intelligently because he could not show prejudice as a result of the court's errors. Because defendant's sentences were jointly-recommended nonmandatory consecutive sentences, the trial court was not required to make the consecutive-sentences findings. Because defendant's sentences were jointly recommended and authorized by law, the sentences are not subject to appellate review pursuant to R.C. 2953.08(D)(1).