State v. Baker

Summary

The Fifth District Court of Appeals of Ohio affirmed William Baker’s convictions and sentence following his guilty plea to aggravated possession of drugs. The court rejected his ineffective-assistance claim concerning counsel’s failure to seek waiver of the mandatory fine and upheld the constitutionality of the Reagan Tokes Act.

Holdings

1. Baker failed to establish ineffective assistance because he did not demonstrate a reasonable probability that the trial court would have waived the mandatory fine had counsel filed an affidavit of indigency.
2. The Reagan Tokes Act is constitutional under the federal and Ohio constitutions.

Questions Presented

1. Whether trial counsel rendered ineffective assistance by failing to file an affidavit of indigency or otherwise request waiver of the mandatory $7,500 fine.
2. Whether indefinite prison terms imposed under the Reagan Tokes Act violate the jury-trial guarantee, separation-of-powers principles, or due process under the federal and Ohio constitutions.

Disposition

affirmed