State v. Huff

• Court: Ohio Court of Appeals
• Decided: April 29, 2026
• Docket: 2025CA0044, 2025CA0045, 2025CA0046
• Status: Published

Opinion

[Cite as State v. Huff, 2026-Ohio-1545.]

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT RICHLAND COUNTY, OHIO

STATE OF OHIO Case Nos. 2025CA0044 2025CA0045 Plaintiff - Appellee 2025CA0046

-vs- Opinion And Judgment Entry

SAMANTHA HUFF Appeal from the Richland County Court of Common Pleas, Case Nos. Defendant - Appellant 2024CR0371N, 2024CR0381N, & 2025CR0259N

Judgment: Affirmed

Date of Judgment Entry: April 29, 2026

BEFORE: Andrew J. King, Kevin W. Popham, and David M. Gormley, Judges

APPEARANCES: Jodie Schumacher (Prosecuting Attorney), Megan Hobart, for Plaintiff-Appellee; Felice Harris, for Defendant-Appellant

OPINION Popham, J.,

{¶1} Appellant Samantha Huff (“Huff”) appeals her convictions and sentences

following negotiated guilty pleas in the Court of Common Pleas for Richland County,

Ohio1. For the reasons below, we affirm the judgment of the trial court.

Facts and Procedural History

{¶2} On May 24, 2024, in Court of Common Pleas, Richland County, Ohio, Case

No. 2024 CR 0371 N2, Huff was indicted on one count of aggravated possession of drugs

1 By Judgment Entry filed Sept. 15, 2025, this Court consolidated Huff’s cases for purposes of

appeal. See Fifth Dist.Loc.R. 12. 2 Fifth District Court of Appeals Case No. 2025CA0046. (methamphetamine), in violation of R.C. 2925.11(A)/(C)(1)(a), a felony of the fifth degree.

On August 20, 2024, Huff entered a guilty plea to the charge.

{¶3} On July 11, 2024, in Court of Common Pleas, Richland County, Ohio, Case

No. 2024 CR 0381 N3 Huff was indicted on one count of failure to comply with the order

or signal of a police officer, in violation of R.C. 2921.331(B)/(C)(5)(a)(ii), a felony of the

third degree, and one count of operating a vehicle under the influence of alcohol, in

violation of R.C. 4511.19(A)(1)(a)/(G)(1)(a), a misdemeanor of the first degree. On August

19, 2024, Huff entered guilty pleas to both offenses.

{¶4} On September 11, 2024, the trial court sentenced Huff in both Case No.

2024 CR 0371 N and Case No. 2024 CR 0381 N to forty-eight months of community

control, subject to conditions including residential treatment.

{¶5} On April 4, 2025, in Court of Common Pleas, Richland County, Ohio, Case

No. 2025 CR 0259 N4 Huff was indicted on one count of possession of heroin in an

amount equal to or exceeding fifty grams but less than one hundred grams, in violation of

R.C. 2925.11(A)/(C)(6)(e), a felony of the first degree.

{¶6} On June 3, 2025, the morning scheduled for jury trial in Case No. 2025 CR

0259, Huff appeared with both appointed and newly retained counsel. Huff’s retained

counsel filed several motions, including a motion to continue the trial, which the trial

court denied. Following that ruling, retained counsel withdrew from representation.

{¶7} After consulting with Huff, appointed counsel informed the trial court that

Huff wished to enter a guilty plea to the indictment (2025 CR 0259). The trial court

conducted a plea colloquy pursuant to Crim.R. 11(C)(2) and accepted Huff’s guilty plea.

3 Fifth District Court of Appeals Case No. 2025CA0045. 4 Fifth District Court of Appeals Case No. 2025CA0044. The court deferred sentencing pending the completion of a presentence investigation

report.

{¶8} On June 9, 2025, notices of probation violation were filed in Case Nos. 2024

CR 0371 and 2024 CR 0381. The notices alleged two violations of Huff’s community

control: (1) her guilty plea to the heroin possession charge in Case No. 2025 CR 0259, and

(2) a positive alcohol test.

{¶9} On June 23, 2025, Huff, represented by different counsel than the attorney

who represented her in the heroin possession case, appeared and admitted both probation

violations in each case. The trial court scheduled sentencing in those cases to occur at the

same time as sentencing in Case No. 2025 CR 0259.

{¶10} On July 7, 2025, the trial court conducted a joint sentencing hearing in Case

No. 2025 CR 0259 and for the probation violations in Case Nos. 2024 CR 0371 and 2024

CR 0381. Both of Huff’s counsel were present - the attorney who represented her in the

heroin possession case and the attorney who represented her in the probation violations

cases.

{¶11} On the possession of heroin conviction in Case No. 2025 CR 0259, the trial

court sentenced Huff to an indefinite prison term of a mandatory minimum of four years

and a potential maximum of six years. With respect to the probation violations related to

Huff’s conviction for failure to comply with the order or signal of a police officer (Case No.

2024 CR 0381), the trial court imposed a twelve-month prison term, to be served

consecutively to the sentence imposed in Case No. 2025 CR 0259.

{¶12} Finally, for the probation violations related to Huff’s aggravated possession

of drugs conviction (Case No. 2024 CR 0371), the trial court imposed a twelve-month prison term to be served concurrently with the sentence in Case No. 2024 CR 0381, but

consecutively to the sentence imposed in Case No. 2025 CR 0259.

Assignments of Error

{¶13} Huff now appeals, raising the following two assignments of error,

{¶14} “I. SAMANTHA HUFF'S GUILTY PLEA WAS NOT KNOWINGLY,

INTELLIGENTLY AND VOLUNTARILY ENTERED AS SHE TENDERED

PROTESTATIONS OF INNOCENCE DURING THE PLEA PROCEEDINGS AND THE

TRIAL COURT FAILED TO ENGAGE IN A HEIGHTENED ALFORD INQUIRY.”

{¶15} “II. PROBATION VIOLATION #1 WAS NOT SUPPORTED BY A

PREPONDERANCE OF SUBSTANTIAL COMPETENT, CREDIBLE EVIDENCE.”

I.

{¶16} In her first assignment of error, Huff argues that the trial court should not

have accepted her guilty plea because she maintained her innocence during the plea

hearing. She contends that her statements constituted a protestation of innocence

requiring the trial court to conduct the enhanced inquiry associated with an Alford plea.

Because the trial court did not conduct such an inquiry, Huff maintains that her plea was

not knowingly, intelligently, and voluntarily entered. We disagree.

Governing Principles

{¶17} "A criminal defendant does not have a constitutional right to enter a guilty

plea or to have it accepted by the court." State ex rel. Bates v. Court of Appeals for the

Sixth Appellate Dist., 2011-Ohio-5456, ¶ 27, citing Santobello v. New York, 404 U.S. 257,

262 (1971); North Carolina v. Alford, 400 U.S. 25, 38, fn. 11. Accord, State v. Belton,

2016-Ohio-1581, ¶ 50. Instead, state law governs the exercise of the defendant’s ability to

plead guilty. Bates, at ¶ 28 citing Alford at 38, fn. 11. In Ohio, a trial court may refuse to accept a guilty plea. Crim.R. 11(C)(2). It seems logical, therefore, to conclude that a trial

court may refuse to accept an Alford plea.

North Carolina v. Alford, 400 U.S. 25 (1970)

{¶18} In North Carolina v. Alford, the United States Supreme Court addressed

the constitutional validity of a guilty plea entered by a defendant who simultaneously

maintained his innocence.

{¶19} Under state law, Alford faced the death penalty if he was convicted after a

jury trial for first-degree murder. State law further provided for a sentence of life

imprisonment upon entering a guilty plea to first-degree murder, and a sentence of

between two to thirty years for a guilty plea to second-degree murder.

{¶20} Alford, charged with first-degree murder and facing the possibility of the

death penalty, pleaded guilty to second-degree murder to avoid the risk of capital

punishment. Although he denied committing the offense, he acknowledged that his plea

was motivated by the strength of the State’s evidence and his desire to limit potential

punishment. Before the plea was finally accepted by the trial court, the court heard the

sworn testimony of a police officer who summarized the State's case. Two other witnesses

besides Alford were also heard. Alford later claimed his guilty plea was involuntary

because its principal motivation was fear of the death penalty.

{¶21} The United States Supreme Court held that the acceptance of a plea

while a defendant maintains his innocence does not violate the Constitution, provided it

represents a voluntary and intelligent choice among the alternatives available to the

defendant. The Court emphasized that a guilty plea is not rendered involuntary merely

because it is entered to avoid the possibility of a harsher penalty, including death. Rather, the dispositive inquiry is whether the defendant, with the advice of competent counsel,

made a rational decision in light of the circumstances.

{¶22} Significantly, the Court concluded that an express admission of guilt is not

a constitutional prerequisite to the imposition of a criminal sentence. Where the record

contains strong evidence of actual guilt and the defendant knowingly and voluntarily

elects to plead guilty, a court may accept the plea notwithstanding the defendant’s

protestations of innocence. In this respect, the Court analogized such pleas to pleas of

nolo contendere, which similarly permit conviction without an explicit admission of guilt.

{¶23} Accordingly, Alford establishes that a defendant may constitutionally enter

a guilty plea while maintaining innocence, so long as the plea is supported by a factual

basis and reflects a voluntary, knowing, and intelligent choice. This principle has come to

be known as an “Alford plea.”

Governing Law: Alford Pleas

{¶24} An Alford plea is a guilty plea accompanied by a contemporaneous

protestation of innocence. North Carolina v. Alford, 400 U.S. 25 (1970). As explained by

the Second District Court of Appeals:

Because an Alford plea involves a rational calculation that is

significantly different from the calculation made by a defendant who admits

guilt, the obligation of the trial judge with respect to accepting such a plea

is correspondingly different. The trial judge must ascertain that,

notwithstanding the defendant’s protestations of innocence, the defendant

has made a rational calculation that it is in his or her best interest to accept

the plea bargain offered by the prosecutor. Where the defendant interjects protestations of innocence into the

plea proceedings and fails to recant those protestations, the trial court must

determine that the defendant has made a rational decision to plead guilty

despite a belief in his or her innocence. This requires, at a minimum, inquiry

of the defendant concerning the reasons for entering the plea and may also

require inquiry into the state’s evidence to determine whether the likelihood

of conviction is sufficiently great to justify the decision.

State v. Padgett, 67 Ohio App.3d 332, 338-339 (2d Dist. 1990).

{¶25} The United States Supreme Court has likewise cautioned that guilty pleas

accompanied by claims of innocence should not be accepted unless the trial court

establishes a factual basis for the plea and resolves the apparent conflict between the

defendant’s waiver of trial and the assertion of innocence. Alford, 400 U.S. at 38, fn. 10.

Requirements for Accepting an Alford Plea

{¶26} A court may accept an Alford plea if the record affirmatively demonstrates

that:

1. the defendant’s plea was not the result of coercion, deception, or

intimidation,

2. counsel was present at the time the plea was entered,

3. counsel’s advice was competent under the circumstances,

4. the defendant understood the nature of the charges, and

5. the defendant was motivated by a desire to obtain a lesser penalty

or avoid the risk of trial. State v. Piacella, 27 Ohio St.2d 92 (1971), paragraph one of the syllabus; see also State v.

Hutchison, 2018-Ohio-200, ¶ 55 (5th Dist.).

{¶27} Accordingly, when it affirmatively appears that a defendant seeks to enter

an Alford plea, the trial court must conduct a more detailed Crim.R. 11 colloquy to

determine the defendant’s reasoning for pleading guilty despite maintaining innocence.

State v. McKinley, 2015-Ohio-2436, ¶ 16 (5th Dist.), citing State v. Hayes, 101 Ohio

App.3d 73 (3d Dist. 1998); see also State v. Grant, 2023-Ohio-4614, ¶ 12 (5th Dist.); State

v. Marchak, 2022-Ohio-2611, ¶ 37 (5th Dist.); State v. Underwood, 2018-Ohio-730, ¶ 18

(5th Dist.). In addition, the record must contain strong evidence of guilt before an Alford

plea may be accepted. McKinley, ¶ 19, citing State v. Scott, 2001-Ohio-2098 (3rd Dist.).

Application

{¶28} In the present case, the record does not demonstrate that Huff entered an

Alford plea. The written plea form contains no reference to an Alford plea, and neither

Huff nor her attorney expressly stated that Huff was entering an Alford plea during the

change-of-plea hearing.

{¶29} Huff nevertheless argues that statements she made during the hearing

constituted protestations of innocence sufficient to trigger the enhanced inquiry required

for an Alford plea. During the hearing, Huff stated:

MS. HUFF: I didn't know anything about the stuff [the heroin] is

what I'm saying to you.

THE COURT: If you want to take it to trial, we will take it to trial.

MS. HUFF: And then lose my son for 14 years, no, I'm not doing that.

THE COURT: Ma'am, that is a choice you have to make. As I

indicated to you, you are saying you are innocent. I can't take your plea if you continue to say that you are innocent and you don't admit that you did

anything wrong. A change of plea is an admission that you did something

wrong.

MS. HUFF: I'm terrified, Judge. I'm not going to sit here and lie. I'm

terrified.

THE COURT: Miss Huff, the time to be terrified is over. The

allegations are that you have already done this. You should have been

terrified at that point in time, not now.

MS. HUFF: I was. Understood.

THE COURT: Ultimately, if you maintain that you are innocent and

do not admit the offense, this case will proceed to trial this afternoon. You

are entitled to that.

(Plea T. at 10-12.)

{¶30} After this exchange, the trial court permitted Huff to consult privately with

counsel. When the proceedings resumed, defense counsel informed the court that Huff

wished to proceed with the guilty plea. Following that consultation, Huff made no further

protestations of innocence and confirmed her desire to plead guilty.

{¶31} The record therefore supports the conclusion that Huff’s plea was a

voluntary, intelligent, and rational decision. At the outset of the hearing, the trial court

outlined the terms of the negotiated resolution, which included the heroin possession

charge and the two community control violation cases. (Plea T. at 4-6.) The agreement

also allowed Huff to remain on bond for approximately six weeks before sentencing so

that she could arrange her affairs. (Plea T. at 6-7.) The judge noted that this was Huff’s sixth felony case. (Plea T. at 10). The judge further informed Huff that the first-degree

felony charge (Possession of Heroin) carried a potential maximum penalty of eleven

years. (Plea T. at 15).

{¶32} Before accepting Huff’s plea, the trial court conducted a thorough Crim.R.

11(C) colloquy. Huff acknowledged that she understood the charges, the potential

penalties, the plea agreement, and the constitutional rights she was waiving by entering a

guilty plea. The record reflects that the trial court strictly complied with the constitutional

advisements required by Crim.R. 11 and substantially complied with nonconstitutional

advisement requirements.

{¶33} The record further demonstrates that the trial court had a factual basis for

accepting the plea. The prosecutor explained that, if the case proceeded to trial, the State

would present evidence that:

On February 25th of this year, at approximately 11:30 p.m., Huff’s

probation officer conducted a home inspection and discovered nearly fifty-

four grams of pure heroin inside the couch where Huff was seated, along

with her house keys.

(Plea T. at 19.)

{¶34} Huff acknowledged that she understood the State’s allegations and

confirmed that she had reviewed the written plea form with her attorney and was satisfied

with counsel’s representation.

{¶35} Huff faced a potential sentence of fifteen years’ imprisonment. (Plea T. at

5). Huff’s motivation for the plea was to limit the amount of time she would be separated

from her child. (Plea T. at 9, 11). Under these circumstances, the record supports the trial court’s determination that Huff knowingly, intelligently, and voluntarily entered her

guilty plea.

{¶36} Because Huff did not persist in a protestation of innocence after consulting

with her attorney, the enhanced Crim.R. 11 inquiry applicable to an Alford plea was not

required. Huff has failed to suggest how the result of the proceedings would have been

different had the Alford cautions been given. Huff was given the opportunity to have a

jury trial in her case, which she declined.

Conclusion

{¶37} The record demonstrates that the trial court complied with the

requirements of Crim.R. 11 and properly accepted Huff’s guilty plea. Accordingly, Huff’s

first assignment of error is overruled.

II.

{¶38} In her second assignment of error, Huff contends that the trial court erred

in revoking her community control based upon her guilty plea to the heroin possession

charge in Case No. 2025 CR 0259. Huff argues that the violation was not supported by

competent, credible evidence because her guilty plea to the possession charge was not

knowingly, intelligently, and voluntarily entered. Specifically, she asserts that the trial

court failed to conduct the additional inquiries required for an Alford plea. We disagree.

{¶39} As discussed in our resolution of Huff’s first assignment of error, the record

supports the trial court’s determination that Huff knowingly, intelligently, and voluntarily

entered her guilty plea to the possession of heroin charge. The record further

demonstrates that Huff did not persist in a protestation of innocence during the plea proceedings, and therefore the enhanced Crim.R. 11 inquiry applicable to an Alford plea

was not required.

{¶40} Because Huff’s guilty plea was validly entered, her admission to the

community control violations based upon the conviction for possession of heroin

constitutes competent and credible evidence that she violated the conditions of her

community control.

{¶41} Accordingly, the record contains sufficient competent, credible evidence to

support the trial court’s decision to revoke Huff’s community control.

{¶42} Huff’s second assignment of error is overruled.

For the reasons stated in our Opinion, the judgments of the Court of Common Pleas

for Richland County, Ohio in Case No. 2025 CR 0259, Case No. 2024 CR 0371 and Case

No. 2024 CR 0381 are affirmed. Cost to be paid by Appellant Samantha Huff.

By: Popham, J.,

King, P.J., and

Gormley, J., concur