State v. Ward

Citations

• 2019 Ohio 4148

Syllabus

COUNSEL – GUILTY PLEA – CRIM.R. 11(E) – JURY WAIVER – CONSTITUTIONAL LAW/CRIMINAL – SIXTH AMENDMENT: The trial court did not violate defendant's right to autonomy by proceeding to a bench trial on a petty offense because, by failing to file a timely jury demand, defendant waived his right to a jury trial. In the absence of evidence of defendant's timely communication to counsel regarding a desire to have a petty offense tried before a jury, counsel's decision to try a petty offense to the court rather than a jury is a strategic decision and does not constitute deficient performance. Defendant's guilty plea to a petty offense was knowingly, intelligently, and voluntarily entered where the trial court informed defendant pursuant to Crim.R. 11(E) that a plea of guilty is a complete admission of guilt.