State v. Bakos

2025 Ohio 1272
CourtOhio Court of Appeals
DecidedApril 11, 2025
Docket2024-CA-40
StatusPublished
Cited by1 cases

This text of 2025 Ohio 1272 (State v. Bakos) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Bakos, 2025 Ohio 1272 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Bakos, 2025-Ohio-1272.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT GREENE COUNTY

STATE OF OHIO : : Appellee : C.A. No. 2024-CA-40 : v. : Trial Court Case No. 2024CR0199 : SAMUEL JOSEPH BAKOS : (Criminal Appeal from Common Pleas : Court) Appellant : :

...........

OPINION

Rendered on April 11, 2025

L. PATRICK MULLIGAN & FRANK MATTHEW BATZ, Attorneys for Appellant

MEGAN A. HAMMOND, Attorney for Appellee

.............

HUFFMAN, J.

{¶ 1} Defendant-Appellant Samuel Joseph Bakos appeals from his conviction

following his guilty pleas to two counts of felonious assault, felonies of the second degree,

and one count of operating a vehicle under the influence, a misdemeanor of the first

degree.

{¶ 2} Bakos argues that various acts of ineffective assistance of counsel rendered -2-

his guilty pleas invalid. For the reasons outlined below, we conclude that he has not

demonstrated any ineffective assistance of counsel adversely affecting the validity of his

pleas. Accordingly, the judgment of the trial court is affirmed.

I. Background Facts and Procedural History

{¶ 3} In September 2023, Bakos was indicted in the Greene County Common

Pleas Court in Case No. 2023 CR 0512 on two counts of aggravated vehicular assault in

violation of R.C. 2903.08(A)(1)(a), felonies of the third degree, and two counts of

operating a vehicle under the influence of alcohol/drugs in violation of R.C.

4511.19(A)(1)(a) and R.C. 4511.19(A)(1)(f), misdemeanors of the first degree. Each of

the aggravated vehicular assault charges carried a maximum prison sentence of up to

five years with mandatory terms.

{¶ 4} Bakos was later charged by way of a bill of information in the Greene County

Common Pleas Court in Case No. 2024 CR 0199 with two counts (counts one and two)

of felonious assault in violation of R.C. 2903.11(A)(2), felonies of the second degree, and

a third count of operating a vehicle under the influence in violation of R.C.

4511.19(A)(1)(a), a misdemeanor of the first degree. The parties filed a joint motion to

dismiss the indictment in Case No. 2023 CR 0512 without prejudice, which the trial court

granted.

{¶ 5} The matter proceeded on Case No. 2024 CR 0199, and Bakos pleaded guilty

as charged. During the plea hearing, he specifically agreed to plead guilty to counts one

and two, both felonies of the second degree, and to count three, a misdemeanor of the

first degree, by way of a plea agreement. The trial court advised him that each of the two -3-

counts of felonious assault carried a minimum prison term of two years up to a maximum

of eight years, potentially resulting in a maximum aggregate prison term of 16 years (none

of which was mandatory). He verbalized his understanding of the terms of the agreement.

{¶ 6} The trial court sentenced Bakos to an indefinite prison term of 8 to 12 years

on count one for felonious assault, to run concurrently with a definite prison term of 8

years on count two, and to a mandatory term of 3 days local jail time on count three to be

subsumed into the sentence, for an aggregate sentence of 8 to 12 years. This appeal

followed.

II. Analysis

{¶ 7} Bakos’s sole assignment of error states:

APPELLANT WAS SUBJECT TO THE INEFFECTIVE

ASSISTANCE OF COUNSEL AS HE DID NOT KNOWINGLY,

INTELLIGENTLY, AND VOLUNTARILY ENTER THE PLEA AGREEMENT.

{¶ 8} On appeal, Bakos asserts that the original charges brought against him in

Case No. 2023 CR 0512 included two misdemeanor charges and two third-degree

felonies that carried a maximum sentence of just over eight years. He contends that he

was not properly counseled regarding the sentencing consequences of accepting the plea

agreement in Case No. 2024 CR 0199, which carried a potentially longer maximum

sentence than the original indictment. He argues that he could not have knowingly,

intelligently, and voluntarily entered his guilty plea without having information regarding

the maximum penalty under the plea agreement as compared to the original charges. For

these reasons, he contends that counsel’s performance was deficient given the -4-

calculation of possible sentences, his negotiation of the plea agreement, his advice to

Bakos to accept the plea agreement, and his failure to assure that the bill of information

was correct when transferring the charges from the original case.

{¶ 9} We review alleged instances of ineffective assistance of counsel under the

two-part analysis found in Strickland v. Washington, 466 U.S. 668 (1984), which the Ohio

Supreme Court adopted in State v. Bradley, 42 Ohio St.3d 136 (1989). To prevail on an

ineffective-assistance claim, a defendant must show that trial counsel rendered deficient

performance and that counsel’s deficient performance prejudiced him. Strickland at

paragraph two of the syllabus; Bradley at paragraph two of the syllabus. “A plea of guilty

waives any claim that the accused was prejudiced by ineffective assistance of trial

counsel, except to the extent that the ineffectiveness alleged may have caused the guilty

plea to be less than knowing, intelligent, and voluntary.” State v. Stivender, 2011-Ohio-

247, ¶ 15 (2d Dist.).

{¶ 10} Trial counsel is entitled to a strong presumption that his or her conduct falls

within the wide range of reasonable assistance. State v. Dunn, 2024-Ohio-600, ¶ 19 (2d

Dist.). “Debatable strategic and tactical decisions may not form the basis of a claim for

ineffective assistance of counsel, even if, in hindsight, it looks as if a better strategy had

been available.” State v. Hall, 2021-Ohio-1894, ¶ 55 (2d Dist.), citing State v. Cook, 65

Ohio St.3d 516, 524 (1992). We will not second-guess decisions of counsel that may be

considered matters of strategy. Id., citing State v. Smith, 17 Ohio St.3d 98 (1985).

{¶ 11} Additionally, off-the-record events or conversations will not support an

ineffective-assistance claim on direct appeal. State v. King, 2024-Ohio-4705, ¶ 10 (2d -5-

Dist.), citing State v. McElrath, 2024-Ohio-2475, ¶ 21 (2d Dist.); see also State v. Jordan,

2021-Ohio-2332, ¶ 24 (2d Dist.), citing State v. Qualls, 2015-Ohio-2182, ¶ 15 (2d Dist.)

(“[T]he record does not reveal what discovery defense counsel shared with Jordan or

what counsel told him regarding a guilty plea . . . Because these arguments rely on

information outside the record, they are not cognizable on direct appeal.”).

{¶ 12} Upon review, we see no ineffective assistance of counsel affecting the

validity of Bakos’s guilty plea. Bakos contends that his trial counsel recommended that

he plead guilty to the two second-degree felony counts in the bill of information, although

he was originally charged with two third-degree felony counts, and that counsel’s

recommendation concerning the bill of information carried a potentially longer maximum

sentence than the original indictment.

{¶ 13} Regarding Bakos’s knowledge of the charges against him to which he

pleaded guilty and the possible sentences for those charges, he was informed of the

same during his plea hearing. The terms of the plea agreement were recited into the

record, and Bakos acknowledged his understanding of the agreement and that he had

reviewed the agreement with his trial counsel.

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Bluebook (online)
2025 Ohio 1272, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bakos-ohioctapp-2025.