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Ohio Case Law

State v. Bowen, 2025-Ohio-2610

Case Information

Court: Court of Appeals of Ohio, Second Appellate District, Montgomery County
Date: 2025-07-25
Citation: 2025-Ohio-2610
Read the Opinion

Summary

Summary: The appellate court affirmed the trial court’s denial of the Defendant’s motion to withdraw his guilty plea to charges of domestic violence and assault, concluding the plea was knowingly and voluntarily entered and supported by a sufficient factual basis.

Key Holdings

  • A plea is valid under Crim.R. 11(B) when the trial court properly advises the defendant of constitutional rights and determines the plea is made knowingly and voluntarily
  • A motion to withdraw a guilty plea made after sentencing is only granted to correct a manifest injustice
  • The existence of a factual basis for the plea may be confirmed through a prosecutor’s statement or defendant’s admissions
  • The trial court has discretion to deny a plea withdrawal motion when the defendant was represented and the plea proceedings show full understanding of rights

More Information

The Defendant pleaded guilty to domestic violence and assault charges following an incident involving his partner, and was sentenced to concurrent jail terms. He later filed a pro se motion to withdraw his plea, claiming coercion and ineffective assistance of counsel. The trial court denied the motion without a hearing, finding no manifest injustice.

On appeal, the Defendant argued that his plea was not voluntary and that the trial court should have held a hearing. The appellate court reviewed the plea colloquy and found the trial court fully complied with Crim.R. 11, ensuring the Defendant understood his rights and the consequences of the plea. The Defendant affirmed he was satisfied with counsel and voluntarily waived his trial rights.

The court also found that the record contained a sufficient factual basis for the plea, including the prosecutor’s summary and the Defendant’s acknowledgment of the facts. The claim that the Defendant was misled or lacked understanding was contradicted by the record.

Because the Defendant failed to demonstrate a manifest injustice as required for post-sentence plea withdrawals, and the trial court’s findings were supported by the record, the appellate court affirmed the denial of the motion.