State v. Rogan, 2025-Ohio-2468
Case Information
Court: Court of Appeals of Ohio Second Appellate District Champaign County
Date: 2025-07-11
Citation: 2025-Ohio-2468
Read the Opinion
Summary
Summary: The appellate court affirmed Defendant’s conviction following his guilty plea to drug charges, rejecting his claim of ineffective assistance of counsel regarding sentencing expectations.
Key Holdings
- A guilty plea waives all appealable errors including ineffective assistance claims except those impacting the voluntariness of the plea
- Ineffective assistance claims must be supported by evidence in the record to be considered on direct appeal
- A defendant must show a reasonable probability that but for counsel’s errors he would have gone to trial
More Information
The Defendant was arrested after a police encounter led to the discovery of drugs and drug-related paraphernalia, corroborated by statements and phone data. He was indicted on six counts related to drug possession, trafficking, and tampering with evidence. He entered a plea agreement, pleading guilty to two charges in exchange for dismissal of the others and a jointly recommended 36-month prison sentence. The court sentenced him accordingly.
The Defendant did not appeal within the standard timeframe but was allowed to file a delayed appeal, claiming ineffective assistance of counsel. He alleged his attorney misled him about early release eligibility, stating he would only serve 18 months.
The appellate court applied the Strickland v. Washington standard, requiring both deficient performance and resulting prejudice. The court noted that a guilty plea limits appellate claims unless counsel’s errors invalidated the plea’s voluntariness. The Defendant confirmed in court that he agreed to a 36-month term and that no other promises were made, undermining his claim.
Because his allegations depended on conversations outside the record, the court found the claim inappropriate for direct appeal and affirmed the trial court’s decision.