State v. Light

2025 Ohio 4628
CourtOhio Court of Appeals
DecidedOctober 6, 2025
Docket14-25-08
StatusPublished

This text of 2025 Ohio 4628 (State v. Light) 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. Light, 2025 Ohio 4628 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Light, 2025-Ohio-4628.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT UNION COUNTY

STATE OF OHIO, CASE NO. 14-25-08 PLAINTIFF-APPELLEE,

v.

ERIC BENJAMIN LIGHT, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

Appeal from Union County Common Pleas Court Trial Court No. 2024-CR-0098

Judgment Affirmed

Date of Decision: October 6, 2025

APPEARANCES:

Alison Boggs for Appellant

Raymond Kelly Hamilton for Appellee Case No. 14-25-08

WALDICK, P.J.

{¶1} Defendant-appellant, Eric B. Light (“Light”), brings this appeal from

the January 30, 2025, judgment of the Union County Common Pleas Court. On

appeal, Light argues that the trial court erred by denying his presentence motion to

withdraw his guilty plea, and that he received ineffective assistance of counsel. For

the reasons that follow, we affirm the judgment of the trial court.

Background

{¶2} On May 17, 2024, Light was indicted for Strangulation in violation of

R.C. 2903.18(B)(2), a third degree felony, Felonious Assault in violation of R.C.

2903.11(A)(1), a second degree felony, Domestic Violence in violation of R.C.

2919.25(A), a first degree misdemeanor, and Aggravated Menacing in violation of

R.C. 2903.21(A), a first degree misdemeanor. It was alleged that Light had an

altercation with his girlfriend wherein Light strangled and struck his girlfriend,

leaving her visibly bruised. Further, it was alleged that during the altercation Light’s

girlfriend suffered a fractured bone in her hand. Law enforcement was called by the

victim’s father while Light was not present. Officers who responded observed

injuries on Light’s girlfriend and she was taken to the hospital for evaluation. Light

originally pled not guilty to the charges.

-2- Case No. 14-25-08

{¶3} After multiple pretrial hearings, a jury trial was set for December 2-4,

2024. However, on November 26, 2024, the parties entered into a written negotiated

plea agreement wherein Light agreed to plead guilty to a reduced, amended charge

of Strangulation in violation of R.C. 2903.18(B)(3), a fifth degree felony. In

exchange, the State agreed to dismiss the remaining charges.

{¶4} The trial court held a Crim.R. 11 change-of-plea hearing and

determined that Light was entering a knowing, intelligent, and voluntary plea.

Light’s plea was accepted, a pre-sentence investigation was ordered, and sentencing

was set for January 16, 2025.

{¶5} When the matter convened for the scheduled sentencing hearing,

Light’s attorney indicated he had just been informed by Light that Light wanted to

withdraw his guilty plea. Light’s attorney stated that Light’s request caught him “off

guard” and he was not prepared to argue a motion to withdraw Light’s plea that day.

The trial court indicated it would set a hearing date on the motion to withdraw, and,

in the meantime, Light could file a written motion to withdraw his plea.

{¶6} On January 28, 2025, Light filed a written motion to withdraw his plea.

He argued that presentence motion to withdraw pleas should be “freely and liberally

granted,” and that the State would experience minimal prejudice due to the

withdrawal. He also contended that on the date of the plea hearing he expressed

some reservations when the State recited a factual basis for the charges.

-3- Case No. 14-25-08

{¶7} In addition, Light contended that in the pre-sentence investigation he

maintained his innocence. Further, he argued that the alleged victim had been

inconsistent and reluctant to appear or cooperate in the prosecution. In fact, he

argued that, “The State is in possession of a written recantation of the allegations by

the alleged ‘victim.’” (Doc. No. 45). Light also argued, for apparently the first time,

that he had an alibi, claiming that he “was at work for 3 hours already when this

allegedly happened.” (Id.)

{¶8} The State filed a response contending that Light was simply having a

“change of heart,” which was not a sufficient basis to withdraw a plea. The State

referenced the change-of-plea hearing wherein Light indicated he fully understood

what he was doing. Further, the State argued that it would be prejudiced by Light’s

withdrawal, particularly because Light had been speaking to the victim.

{¶9} On January 30, 2025, the trial court held a hearing on Light’s motion to

withdraw his guilty plea. Light’s counsel orally argued in favor of the motion to

withdraw, contending that Light had maintained his factual innocence. In addition,

Light’s counsel argued that the alleged victim had been arrested on drug charges

making it easier for the State to secure her testimony at trial, thus there could be

little prejudice to the State.

{¶10} The State argued that Light had six months to assert an alibi prior to

his plea or scheduled trial date and he was only just raising the issue. The State also

-4- Case No. 14-25-08

presented a short segment of a phone call between Light and the alleged victim from

October 6, 2024, wherein Light was attempting to get money and the alleged victim

stated she was “trying to avoid the court for a reason.” (Jan. 30, 2025, Tr. at 10).

Light responded that he was aware the victim was trying to avoid court. The State

argued that Light was tampering with the alleged victim and that the alleged victim

was afraid of Light as shown on police body camera footage from the date of the

alleged incident.

{¶11} Following the arguments of the parties, the trial court conducted a

lengthy analysis on the record and ultimately overruled Light’s motion to withdraw

his plea. The trial court then proceeded to sentencing and reviewed Light’s criminal

history, which included multiple prior felonies. After reviewing the sentencing

factors, the trial court sentenced Light to five years of community control.

{¶12} The trial court filed a final judgment entry denying Light’s motion to

withdraw and sentencing him to community control on January 30, 2025. It is from

this judgment that Light appeals, asserting the following assignments of error for

our review.

First Assignment of Error

The trial court erred when it overruled Appellant’s motion to withdraw his plea before he was sentenced.

-5- Case No. 14-25-08

Second Assignment of Error

Appellant was denied the effective assistance of counsel as guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution and Article I, Section 10 of the Ohio Constitution.

{¶13} In his first assignment of error, Light argues that the trial court abused

its discretion by denying his presentence motion to withdraw his guilty plea.

Standard of Review

{¶14} Criminal Rule 32.1 governs the withdrawal of guilty pleas and it reads,

“A motion to withdraw a plea of guilty or no contest may be made only before

sentence is imposed; but to correct manifest injustice the court after sentence may

set aside the judgment of conviction and permit the defendant to withdraw his or

her plea.”

{¶15} The Supreme Court of Ohio has emphasized that “ ‘[a] presentence

motion to withdraw a guilty plea should be freely and liberally granted.’ ” State v.

Barnes, 2022-Ohio-4486, ¶ 13, quoting State v. Xie, 62 Ohio St.3d 521, 527 (1992).

However, the Supreme Court of Ohio continued by indicating that a defendant does

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Bluebook (online)
2025 Ohio 4628, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-light-ohioctapp-2025.