State v. Cottrell

Ohio Court of Appeals·Decided June 15, 2026·No. 25AP0039·Published

Opinion

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF WAYNE )

STATE OF OHIO C.A. No. 2025AP0039 Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE

CHAD COTTRELL COURT OF COMMON PLEAS COUNTY OF WAYNE, OHIO

Appellant CASE No. 2024 CRC-I 000138

DECISION AND JOURNAL ENTRY Dated: June 15, 2026

STEVENSON, Judge.

{¶1} Defendant-Appellant Chad Wesley Cottrell appeals from the judgment of the Wayne County Court of Common Pleas denying his post-sentence motion to withdraw his no contest pleas. We affirm.

I.

{¶2} The Wayne County Grand Jury indicted Mr. Cottrell in April 2024 with four counts of attempted aggravated arson in violation of R.C. 2923.02 and R.C. 2909.02(A)(1), felonies of the second degree, involving four separate victims, and one count of attempted arson in violation of R.C. 2923.02 and R.C. 2909.02(A)(2), a felony of the third degree. He pleaded not guilty at arraignment and counsel was appointed to represent him. Mr. Cottrell was held without bond and a pretrial was set.

{¶3} Counsel for Mr. Cottrell moved for a competency evaluation after the arraignment.

The trial court found in September 2024 that Mr. Cottrell was “not presently competent to stand

trial but that he may be restored to competency within the time period required under the law.” Mr. Cottrell was “committed to the Ohio Department of Mental Health and Addiction Services for restoration treatment services[.]” Mr. Cottrell was determined to be “restored and competent to stand trial” on February 3, 2025.

{¶4} Mr. Cottrell appeared before the trial court with counsel for a pretrial conference on February 26, 2025. The State informed the trial court at this pretrial that Mr. Cottrell would “be pleading guilty to all the charges in the indictment” and that “there will be no agreement on sentencing[.]” Defense counsel confirmed this representation and Mr. Cottrell signed a written plea form acknowledging that he was entering “a Plea of Guilty/No Contest with full knowledge of the other alternatives available to me.” The trial court then inquired as follows:

THE COURT: So, Mr. Cottrell, it’s your desire to enter into this plea agreement here today, is that correct?

MR. COTTRELL: Yes, Your Honor.

THE COURT: All right, I’m going to ask you some questions to determine, to make sure that you understand everything that is happening here. . . .

...

THE COURT: So, you reviewed the plea form, were you able to read that?

MR. COTTRELL: Yes.

THE COURT: Okay, and you signed it?

MR. COTTRELL: Yes, Your Honor.

...

THE COURT: You’re represented by Mr. Pyle, do you feel that you’ve had a fair and reasonable opportunity to talk to Mr. Pyle about all aspects of your case?

MR. COTTRELL: Yes, Your Honor.

THE COURT: Are you satisfied with his representation?

MR. COTTRELL: Yes, Your Honor.

{¶5} Mr. Cottrell acknowledged that he understood the meaning of a no contest plea as well as the maximum penalties for each count of the indictment. The court read each charge to Mr. Cottrell, and he entered a no contest plea to all five counts of the indictment. The trial court found Mr. Cottrell guilty of all five counts, revoked bond, and ordered a presentence investigation.

{¶6} The trial court held a sentencing hearing on April 9, 2025. Mr. Cottrell was present for the hearing with his counsel. Mr. Cottrell did not raise the issue of his plea or any issues with counsel. The trial court sentenced Mr. Cottrell on Count One, attempted aggravated arson in violation of R.C. 2923.02 and R.C. 2909.02(A)(1), a felony of the second degree, to a prison term of four to six years, with the other counts merging with Count One, with credit for 399 days served, plus time served while awaiting transport. The court informed Mr. Cottrell of post-release control and ordered that he register in the arson registry, explaining how to complete the registration process and the repercussions if he failed to register. Fines and costs were waived, and Mr. Cottrell was advised of his appellate rights.

{¶7} Mr. Cottrell, through counsel, moved to withdraw his no contest pleas1 pursuant to Crim.R. 32.1 on April 18, 2025. Mr. Cottrell argued that he should be allowed to withdraw his pleas “because he was not properly advised that he could assert the ‘Abandonment’ defense” and on the basis that “he was not properly advised that he could withdraw his pleas prior to his sentencing hearing.”

1 Mr. Cottrell’s motion was titled “Motion to Withdraw His Guilty Pleas.” The record is clear that he had entered a no contest plea to each charge in the indictment and this Court will, accordingly, refer to the no contest pleas that were entered in this case.

{¶8} A hearing on Mr. Cottrell’s motion to withdraw his no contest pleas was held before the trial court on May 30, 2025. Defense counsel informed the court at this hearing: “I believe that I really overcame [Mr. Cottrell] or his desire to go to trial and assert the abandonment defense[.]” Counsel said that he had relied on a factually similar case when advising Mr. Cottrell and that he had “pressed [Mr. Cottrell] with that [case] and I think [Mr. Cottrell] just kind of said, well, you know, whatever you think[.]”

{¶9} Mr. Cottrell informed the trial court that he was not going to testify in support of his motion to withdraw his no contest pleas. The following colloquy then occurred:

THE COURT: [Defense counsel], do you want him to testify?

[DEFENSE COUNSEL]: I want to go along with his choice.

MR. COTTRELL: No, you know, I’ll just go with my lawyer, I’m not going to testify.

THE COURT: You’re not going to testify?

MR. COTTRELL: No.

Mr. Cottrell did not call any witnesses to testify on his behalf.

{¶10} Victim T.B. testified at the hearing on Mr. Cottrell’s motion to withdraw his no contest pleas. T.B. testified that she “was in the kitchen” on the day of the incident when she saw Mr. Cottrell with “a gasoline can in his hand.” She testified that she saw Mr. Cottrell go “off [her] porch and around the house” before “throwing the gas can” towards her garage. She then observed Mr. Cottrell come toward the house with a lighter to “light it” on fire. T.M. “slam[med] the door as hard as [she] could to try to startle” Mr. Cottrell. T.M.’s brother was working in the garage at the time and he “came out after him.” T.M. testified that it took her “brother swinging at [Mr. Cottrell] several times for him to get his bike and back away from the house.” Mr. Cottrell’s actions were captured on T.M.’s security camera and the video was admitted into evidence at the oral

hearing. This video was also played at a preliminary hearing that was held before the indictment in this case and at which Mr. Cottrell was present.

{¶11} The trial court denied Mr. Cottrell’s motion to withdraw his no contest pleas, finding that he had failed to demonstrate manifest injustice. Mr. Cottrell appeals, asserting one assignment of error for this Court’s review.

ASSIGNMENT OF ERROR NO. I

THE TRIAL COURT ABUSED ITS DISCRETION BY DENYING [MR.

COTTRELL] THE OPPORTUNITY [TO] WITHDRAW HIS PLEA[.]

{¶12} In his sole assignment of error, Mr. Cottrell contends that the trial court abused its discretion in denying his post-sentence motion to withdraw his no contest pleas. Specifically, Mr. Cottrell argues his trial counsel was ineffective for pressuring him into taking the plea and advising him that there could not be an effective affirmative defense of abandonment.

{¶13} Mr. Cottrell’s motion to withdraw his no contest pleas was filed pursuant to Crim.R.

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