State v. Williams

Citations

• 2020 Ohio 3588

Syllabus

Vindictive sentence, Crim.R. 11, group plea, dual representation, conflict of interest, ineffective assistance of counsel, indigency affidavit, joint plea. Defendant and his spouse were represented by the same counsel at a group plea with defendants in unrelated cases and at the sentencing hearing. The trial court did not impose a vindictive sentence. The trial court's procedure at the group-plea hearing complied with Crim.R. 11. The trial court did not have a duty to inquire about counsel's dual representation of a husband and wife. Defendant failed to show prejudice resulting from counsel's failure to file an indigency affidavit to waive mandatory fine or from counsel's dual representation of defendant and his spouse.