The Ohio Third Appellate District Court of Appeals has affirmed the conviction of Eric Benjamin Light, upholding the decision of the Union County Common Pleas Court. Light had appealed his conviction on two grounds: that the trial court erred in denying his request to withdraw his guilty plea, and that he received ineffective assistance of counsel. The appellate court found both arguments unpersuasive.
Background of the Case
The case stemmed from an incident on May 17, 2024, when Light was accused of assaulting his girlfriend. He was originally indicted on several charges, including strangulation, felonious assault, domestic violence, and aggravated menacing. The allegations included strangulation, physical assault resulting in bruising, and a fractured hand. Light initially pleaded not guilty.
After multiple pre-trial hearings, a plea agreement was reached on November 26, 2024, just before the scheduled jury trial. Light agreed to plead guilty to a reduced charge of strangulation, a fifth-degree felony, in exchange for the dismissal of the remaining charges. The trial court conducted a hearing to ensure Light’s plea was knowing, intelligent, and voluntary. Sentencing was set for January 16, 2025.
At the sentencing hearing, Light’s attorney informed the court that Light wished to withdraw his guilty plea. The court scheduled a hearing on the motion, and Light filed a written motion to withdraw his plea on January 28, 2025.
In his motion, Light argued that presentence motions to withdraw a guilty plea should be “freely and liberally granted.” He also claimed the state would experience minimal prejudice from the withdrawal. Light also contended that he had expressed some reservations about the factual basis for the charges at the plea hearing. Furthermore, Light claimed that the alleged victim had been inconsistent and reluctant to cooperate, and that the state possessed a written recantation of the allegations. For the first time, Light also asserted an alibi, claiming he was at work when the incident allegedly occurred.
The state opposed the motion, arguing that Light was simply having a “change of heart” and that the state would be prejudiced. The state referenced the plea hearing, where Light indicated he understood what he was doing, and that Light had been speaking to the victim.
The trial court held a hearing on January 30, 2025, and ultimately denied Light’s motion to withdraw his plea. The court proceeded with sentencing, reviewing Light’s criminal history, which included multiple prior felonies. Light was sentenced to five years of community control.
Arguments on Appeal: Motion to Withdraw Plea
Light’s first argument on appeal was that the trial court erred in denying his motion to withdraw his guilty plea before sentencing. The court of appeals noted that, generally, presentence motions to withdraw a guilty plea should be “freely and liberally granted.” However, a defendant does not have an absolute right to withdraw a plea. The trial court’s decision on such a motion is reviewed for an abuse of discretion, meaning the decision was arbitrary, unreasonable, or capricious.
The appellate court considered whether the case was similar to the case of *State v. Barnes*, where the Ohio Supreme Court held that a defendant has a reasonable basis to withdraw a guilty plea before sentencing if they learn of new evidence that would have changed their decision to plead guilty.
Light claimed “new evidence” included an alleged recantation by the victim and his alibi. The court found that Light’s alibi claim, which he hadn’t raised earlier, did not constitute new evidence. The court noted that there was no record of an actual recantation, and the court did not know if Light was made aware of the recantation before pleading guilty. Therefore, the court concluded that the *Barnes* precedent did not apply.
Since *Barnes* didn’t apply, the court analyzed the traditional factors used by Ohio appellate courts when reviewing motions to withdraw guilty pleas. The appellate court found that several factors weighed against Light. The court found that the state could be prejudiced by the withdrawal because the victim had been uncooperative. The court also found that Light had competent counsel. The court also found that the plea hearing was thorough and that Light understood the charges and potential sentences. The court also noted that the trial court gave full and fair consideration to the motion. The court ultimately concluded that the trial court did not abuse its discretion in denying Light’s motion to withdraw his guilty plea.
Arguments on Appeal: Ineffective Assistance of Counsel
Light’s second argument was that he received ineffective assistance of counsel. To prove ineffective assistance, a defendant must show that their attorney’s performance was deficient and that this deficiency prejudiced the defendant.
Light argued his attorney was ineffective for several reasons. First, Light claimed his attorney failed to attach the alleged recantation to the motion to withdraw his plea. The court rejected this argument because there was no evidence in the record that the recantation even existed.
Second, Light claimed his attorney was ineffective for failing to object to the introduction of a phone conversation snippet between Light and the victim. The court noted that Light’s counsel did, in fact, object to the phone conversation. The court also found that Light did not establish how the conversation was inadmissible.
Finally, Light argued that his trial counsel was ineffective for failing to properly establish his alibi defense. The court noted that no notice of alibi had been filed and there was no indication that Light actually had an alibi. The court found that Light had not demonstrated ineffective assistance of counsel.
Conclusion
The appellate court found no merit in either of Light’s arguments. The court affirmed the trial court’s denial of Light’s motion to withdraw his guilty plea and the judgment of conviction.