State v. Cyphers

Summary

The Ohio Second District Court of Appeals affirmed Harley Cyphers's murder conviction following his guilty plea. The court held that the plea was knowing, intelligent, and voluntary despite the trial court's denial of funds for a battered-child-syndrome expert and related alleged errors. The court also rejected Cyphers's due-process and ineffective-assistance claims.

Holdings

1. A guilty plea waives appealable pretrial errors, including challenges to pretrial rulings and ineffective-assistance claims, unless the alleged error affected the plea's knowing, intelligent, and voluntary character. Any assumed error in denying funds for a battered-child-syndrome expert did not invalidate Cyphers's plea.
2. Cyphers's guilty plea was knowing, intelligent, and voluntary.
3. The denial of funds for the battered-child-syndrome expert did not violate Cyphers's due-process rights because, despite that ruling, he retained the right to proceed to trial and to appeal the funding decision.
4. Cyphers failed to establish ineffective assistance of counsel.

Questions Presented

1. Whether any error in denying funds for a battered-child-syndrome expert rendered Cyphers's guilty plea unknowing, unintelligent, or involuntary.
2. Whether the denial of expert funding violated Cyphers's due-process right to present a complete defense.
3. Whether the trial court's statements concerning battered-child syndrome and self-defense coerced the guilty plea.
4. Whether trial counsel was ineffective for failing to seek reconsideration of the funding decision, make an evidentiary proffer, or timely file a notice of self-defense.

Disposition

affirmed