State v. Shafer

Summary

The Ohio Second District Court of Appeals affirmed Tyler C. Shafer’s conviction for reckless operation following his negotiated guilty plea. The court rejected Shafer’s ineffective-assistance claim, concluding that the record did not show his plea was unknowing, unintelligent, or involuntary, and that matters outside the record could not be considered on direct appeal.

Holdings

1. Shafer failed to establish ineffective assistance of trial counsel or that his guilty plea was less than knowing, intelligent, and voluntary. The absence of the plea-hearing transcript required the court to presume regularity, and the written plea form indicated that Shafer had been advised of his rights and was satisfied with counsel's advice.
2. The court could not consider evidence outside the record, including alleged off-the-record events or conversations, to support Shafer's ineffective-assistance claim on direct appeal.

Questions Presented

1. Whether Shafer established ineffective assistance of trial counsel that rendered his guilty plea less than knowing, intelligent, and voluntary.
2. Whether the court of appeals could consider alleged coercive communications or other evidence outside the appellate record on direct appeal.

Disposition

affirmed