State v. Wilson

Citations

• 2018 Ohio 3666

Syllabus

Crim.R. 14, joinder severance waiver effective assistance of counsel consecutive sentences nunc pro tunc. Defendant's guilty plea waived his right to challenge the denial of his Crim.R. 14 motion to sever, and he failed to demonstrate how the joinder of his cases affected his decision to enter into a guilty plea. Defendant failed to demonstrate how the trial court's decision denying his motion for removal of counsel affected the knowing and voluntary nature of his plea. He was not denied effective assistance of counsel when counsel agreed to a recommended sentence. The record demonstrated that the sentence was only a recommendation and not binding, and the defendant could have advocated for a lesser sentence. Consecutive sentence findings were properly made and supported by the record the issuance of a nunc pro tunc is the proper remedy when the trial court fails to incorporate those findings in the sentencing journal entry.