State v. Crenshaw

2026 Ohio 186
CourtOhio Court of Appeals
DecidedJanuary 22, 2026
Docket115006
StatusPublished

This text of 2026 Ohio 186 (State v. Crenshaw) 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. Crenshaw, 2026 Ohio 186 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Crenshaw, 2026-Ohio-186.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 115006 v. :

RAYMOND CRENSHAW, JR., :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: January 22, 2o26

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-24-696472-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, Sarah E. Hutnik and Brian Callahan, Assistant Prosecuting Attorneys, for appellee.

Cullen Sweeney, Cuyahoga County Public Defender, and Rick Ferrara, Assistant Public Defender, for appellant.

LISA B. FORBES, J.:

Raymond Crenshaw, Jr. (“Crenshaw”) appeals his conviction for

unlawful possession of dangerous ordnance and sentence to a prison term of six and

one-half years. After a thorough review of the facts and the law, we affirm. I. Procedural History

On October 29, 2024, Crenshaw was one of three defendants named

in a ten-count indictment. Crenshaw was charged with three counts: Count 8,

carrying a concealed weapon, a fourth-degree felony, in violation of

R.C. 2923.12(A)(2); Count 9, unlawful possession of dangerous ordnance, a fifth-

degree felony, in violation of R.C. 2923.17(A), with one- and six-year firearm

specifications under R.C. 2941.141(A) and 2941.144(A), respectively; and Count 10,

obstructing official business, a second-degree misdemeanor, in violation of

R.C. 2921.31(A). All charges were accompanied by a specification for forfeiture of a

weapon, under R.C. 2941.1417(A).

On February 11, 2025, Crenshaw pled guilty to Count 9, unlawful

possession of dangerous ordnance, with a six-year firearm specification under

R.C. 2941.144(A). The State nolled all other counts and specifications.

That same day, the court held a sentencing hearing at which it

imposed upon Crenshaw a prison term of six years on the firearm specification and

six months on the underlying offense, for a total of six and one-half years.

Crenshaw appeals, raising the following assignment of error:

Defense counsel rendered constitutionally ineffective assistance by advising the defendant to enter a plea based on a misunderstanding of sentencing law, unnecessarily and prejudicially guaranteeing that the defendant would receive a mandatory consecutive prison sentence of six years. II. Law and Analysis

To establish ineffective assistance of counsel, a defendant must show

that his attorney was deficient, i.e., that counsel made errors so serious that they

were not functioning as counsel guaranteed by the Sixth Amendment. Strickland v.

Washington, 466 U.S. 668, 687 (1984). Counsel’s errors must also have prejudiced

the defense, meaning that the defendant did not receive a fair trial. Id. To show that

a defendant has been prejudiced by counsel’s deficient performance, the defendant

must prove that there exists a reasonable probability that, were it not for counsel’s

errors, the result of the trial would have been different. State v. Bradley, 42 Ohio

St.3d 136 (1989), paragraph three of the syllabus. “A reasonable probability is a

probability sufficient to undermine confidence in the outcome.” Strickland at 694.

Where a defendant enters a guilty plea, he or she waives a claim of

ineffective assistance of counsel except to the extent that the ineffective assistance

of counsel caused the defendant’s plea to be less than knowing, intelligent, and

voluntary. State v. Parham, 2018-Ohio-1631, ¶ 32 (8th Dist.), citing State v.

Williams, 2014-Ohio-3415, ¶ 11 (8th Dist.). A defendant who has entered a guilty

plea can prevail on a claim of ineffective assistance of counsel only by demonstrating

the following:

“(1) deficient performance by counsel, i.e., that counsel’s performance fell below an objective standard of reasonable representation, that caused the defendant’s guilty plea to be less than knowing, intelligent and voluntary and (2) that there is a reasonable probability that, but for counsel’s deficient performance, the defendant would not have pled guilty to the offenses at issue and would have, instead, insisted on going to trial.” Id., quoting id., citing State v. Xie, 62 Ohio St.3d 521, 524 (1992), and Hill v.

Lockhart, 474 U.S. 52 (1985).

“To ensure that a defendant enters a plea knowingly, voluntarily, and

intelligently, a trial court must engage in an oral dialogue with the defendant in

accordance with Crim.R. 11(C).” Parham at ¶ 9, citing State v. Engle, 74 Ohio St.3d

525, 527 (1996). “The underlying purpose of Crim.R. 11(C) is to convey certain

information to a defendant so that he or she can make a voluntary and intelligent

decision regarding whether to plead guilty.” Id., citing State v. Schmick, 2011-Ohio-

2263, ¶ 5 (8th Dist.).

Crim.R. 11(C)(2)(a) requires, in relevant part, that a court ensure that

a defendant understands the nature of the charges against him and of the maximum

penalty involved before he enters a guilty plea. Crim.R. 11(C)(2)(b) requires that the

court inform a defendant of the effect of a guilty plea, which Crim.R. 11(B)(1)

establishes is a “complete admission of the defendant’s guilt.” Finally,

Crim.R. 11(C)(2)(c) requires a court to inform a criminal defendant that he has a

right to trial, right to confront and cross-examine the State’s witnesses, right to

subpoena and call his own witnesses, right to have the State prove his guilt beyond

a reasonable doubt, and a right to decline to testify.

The record does not indicate that trial counsel caused Crenshaw’s plea

to be less than knowing, voluntary, and intelligent. As required by Crim.R. 11(C)(2)(a), the court explained the possible prison terms that Crenshaw

could receive under the plea agreement, as follows:

The Court: So at a minimum, the Court could give you or would give you the six years and we already talked about that minimum sentence being six months. Do you understand that, sir?

The Defendant: Yes, sir.

The Court: Or 7, 8, 9, 10, 11, or even 12 months. Do you understand that, sir?

The Court: So your maximum exposure . . . could be seven years. Do you understand that, sir?”

Regarding the nature of the offenses against him and the impact of a

guilty plea, under Crim.R. 11(C)(2)(a) and (b), respectively, the court explained that

“by entering into a plea of guilty to this amended indictment you are admitting to

. . . your full guilt,” as to “Count 9, unlawful possession of a dangerous ordnance, a

felony of the fifth degree along with the six-year firearm specification.” Crenshaw

replied, “Yes, sir.” The court then informed Crenshaw that, by pleading guilty, he

forfeited his right to trial, among his other rights under Crim.R. 11(C)(2)(c), all of

which Crenshaw stated that he understood.

In support of his claim that trial counsel was ineffective, Crenshaw

argues that he would have been “better off pleading to the indictment” than

accepting the plea agreement that his attorney negotiated. He contends that, under

the indictment, the court could have sentenced him on the one-year firearm specification, while under the plea agreement, it was required to sentence him on

the six-year specification.1

We acknowledge that the plea agreement required the court to

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
State v. Williams
2014 Ohio 3415 (Ohio Court of Appeals, 2014)
State v. Parham
2018 Ohio 1631 (Ohio Court of Appeals, 2018)
State v. Bradley
538 N.E.2d 373 (Ohio Supreme Court, 1989)
State v. Xie
584 N.E.2d 715 (Ohio Supreme Court, 1992)
State v. Holliman
2025 Ohio 1187 (Ohio Court of Appeals, 2025)

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Bluebook (online)
2026 Ohio 186, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-crenshaw-ohioctapp-2026.