State v. Blanton

Summary

The Supreme Court of Ohio held that res judicata does not bar a postconviction ineffective-assistance-of-counsel claim when the claim cannot be meaningfully reviewed without evidence outside the trial record. The court declined to overrule State v. Cole and reaffirmed Ohio’s two-part framework for determining whether such claims are barred and whether they warrant an evidentiary hearing. Applying that framework, the court affirmed the judgment of the Fourth District Court of Appeals denying relief on Denny Blanton’s postconviction claims.

Holdings

1. Ohio retains the rule that res judicata does not bar a postconviction ineffective-assistance-of-counsel claim when the claim cannot be meaningfully reviewed without resorting to evidence outside the trial record. A claim that could have been fully adjudicated on direct appeal is barred.
2. When a postconviction ineffective-assistance claim relies on evidence outside the record, the court must separately determine whether the petitioner introduced competent outside-the-record evidence and whether that evidence, if believed together with the trial record, would establish deficient performance and prejudice.
3. An ineffective-assistance claim is not barred merely because the evidence supporting it was known or available to the defense at trial. If the trial record does not demonstrate the existence or significance of the evidence, the claim may be raised in postconviction proceedings.
4. The limited exception to res judicata for outside-the-record ineffective-assistance claims does not extend to other constitutional claims. A due-process claim based on the State's failure to preserve evidence is barred when the defense knew of the alleged violation and could have fully litigated it during the trial proceedings.
5. A trial court may assess the credibility of affidavits supporting a postconviction petition and reject purely frivolous claims, but an appellate court may not make that credibility determination in the first instance.

Questions Presented

1. Whether Ohio should abandon or modify the rule that res judicata bars postconviction ineffective-assistance claims when the claims could have been fully adjudicated on direct appeal.
2. Whether an ineffective-assistance claim is barred by res judicata when meaningful review requires evidence outside the trial record, including evidence that was known or available to the defense at trial.
3. Whether Blanton's individual ineffective-assistance claims established substantive grounds for postconviction relief warranting an evidentiary hearing.
4. Whether Blanton's due-process claim based on the State's failure to preserve jail video was barred by res judicata when the defense knew of the alleged failure during the trial-court proceedings.
5. Whether the court of appeals improperly made an initial credibility determination concerning affidavits supporting the postconviction petition.

Disposition

affirmed