State v. Paniagua

2025 Ohio 5800
CourtOhio Court of Appeals
DecidedDecember 30, 2025
DocketCA2025-03-009
StatusPublished

This text of 2025 Ohio 5800 (State v. Paniagua) 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. Paniagua, 2025 Ohio 5800 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Paniagua, 2025-Ohio-5800.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

MADISON COUNTY

STATE OF OHIO, : CASE NO. CA2025-03-009 Appellee, : OPINION AND vs. : JUDGMENT ENTRY 12/30/2025 EFRAIN V. PANIAGUA, :

Appellant. :

:

CRIMINAL APPEAL FROM MADISON COUNTY COURT OF COMMON PLEAS Case No. CRI20210069

Nicholas A. Adkins, Madison County Prosecuting Attorney, and Michael S. Klamo, Assistant Prosecuting Attorney, for appellee.

Web Norman Law, Inc., and William B. Norman, for appellant.

___________ OPINION

M. POWELL, J.

{¶ 1} Appellant, Efrain Paniagua, appeals a decision of the Madison County Court

of Common Pleas denying his postsentence motion to withdraw his guilty plea. Madison CA2025-03-009

{¶ 2} Appellant is a citizen of Mexico. The record indicates he moved to the

United States in 1999, when he was three years old. In April 2021, appellant was indicted

on one count of first-degree felony aggravated possession of drugs and an accompanying

major drug offender specification. The charge arose after police discovered 22 kilograms

of narcotics in the vehicle in which appellant was a passenger.

{¶ 3} On October 1, 2021, the trial court held a plea hearing during which it

engaged in a full and proper Crim.R. 11 colloquy. The trial court also orally advised

appellant, in compliance with R.C. 2943.031, that "a conviction of the offense to which

you are pleading may have the consequences of deportation, exclusion from admission

to the United States, or denial of naturalization pursuant to the laws of the United States."

The court then asked appellant if he understood; appellant replied he did. The trial court

further inquired, "And you've discussed that with [defense counsel]?" Appellant replied,

"Yes, sir." Pursuant to plea negotiations, appellant then pled guilty to a second-degree

felony aggravated possession of drugs, and the major drug offender specification was

dismissed. Appellant was sentenced to an indefinite prison term of five to seven-and-one-

half years.

{¶ 4} On February 7, 2025, appellant moved to withdraw his guilty plea pursuant

to Crim.R. 32.1. on the ground defense counsel's failure to advise him of the immigration

consequences of pleading guilty deprived him of his constitutional right to the effective

assistance of counsel. In support of the motion, appellant attached his own affidavit in

which he averred he is not a United States citizen; he is a citizen of Mexico; he was

brought to the United States when he was three years old; his parents, siblings, and wife

all reside in the United States; and he has little connection to Mexico. Regarding his plea,

appellant further averred that although he repeatedly requested that defense counsel

advise him of the immigration consequences of a guilty plea, defense counsel continually

-2- Madison CA2025-03-009

postponed such discussion and ultimately never discussed with him the immigration

consequences of pleading guilty, including the fact that a conviction for aggravated

possession of drugs would "trigger a conclusive presumption of deportability"; that he

entered his guilty plea with the understanding he could challenge deportation as a

consequence of his guilty plea to a drug offense; that he first learned deportation was

presumptively mandatory in January 2023; and that he would never have pled guilty had

he known that deportation under the circumstances would be mandatory.

{¶ 5} The trial court denied appellant's motion without an evidentiary hearing.

Noting that a Crim.R. 32.1 motion to withdraw a plea may only be granted to correct a

manifest injustice, the trial court found that

[Defendant] cannot reasonably argue that his guilty plea was the product of manifest injustice by virtue of defense counsel's failure to advise him that he could be deported as a consequence of his plea. The Defendant was properly advised of such by the Court and when the Court inquired of whether or not the Defendant had engaged in such conversations with his attorney, the Defendant answered in the affirmative."

{¶ 6} The trial court also found that appellant's claims were barred by res judicata

because his assertions were based upon information available to him at the time he could

have filed a direct appeal, and therefore the issue of ineffective assistance of counsel at

the plea hearing could have been raised on direct appeal but was not.

{¶ 7} Appellant now appeals, raising three assignments of error. Appellant's first

and third assignments of error will be addressed together.

{¶ 8} Assignment of Error No. 1:

THE TRIAL COURT ERRED IN FINDING NO MANIFEST INJUSTICE WARRANTING WITHDRAWAL OF APPELLANT'S GUILTY PLEA.

{¶ 9} Assignment of Error No. 3:

-3- Madison CA2025-03-009

THE TRIAL COURT ERRED IN DENYING RELIEF WITHOUT CONDUCTING AN EVIDENTIARY HEARING.

{¶ 10} In his first assignment of error, appellant argues that the trial court erred in

denying his motion to withdraw his guilty plea on the ground he failed to establish manifest

injustice. Appellant asserts that his R.C. 2925.11(A) aggravated possession of drugs

conviction subjects him to mandatory deportation as a controlled substance conviction

under 8 U.S.C. 1227(a)(2)(B)(i) or as an aggravated felony conviction under 8 U.S.C.

1227(a)(2)(A)(iii), and that had he known of the mandatory deportation consequences, he

would never have pled guilty to aggravated possession of drugs. Appellant also asserts

that "due process principles require this Court to grant an evidentiary hearing to determine

the veracity of [his] claims regarding defense counsel's failure to advise him of the fact

that he was subject to mandatory deportation." In his second assignment of error,

appellant argues that the trial court erred in denying his motion to withdraw his guilty plea

without conducting a hearing on the motion.

{¶ 11} Crim.R. 32.1 allows postsentence withdrawal of a guilty plea in limited

circumstances "to correct a manifest injustice." A defendant seeking to withdraw a guilty

plea after the imposition of sentence bears the burden of establishing the existence of a

manifest injustice. State v. Tapia-Cortes, 2016-Ohio-8101, ¶ 11 (12th Dist.). In general,

manifest injustice relates to a fundamental flaw in the proceedings that results in a

miscarriage of justice or is inconsistent with the demands of due process. Id. A motion

made pursuant to Crim.R. 32.1 is addressed to the sound discretion of the trial court. Id.

at ¶ 12. Consequently, an appellate court will not reverse the trial court's decision absent

an abuse of discretion. Id.

{¶ 12} Ineffective assistance of counsel is a proper basis for seeking a

postsentence withdrawal of a guilty plea, and can constitute a manifest injustice sufficient

-4- Madison CA2025-03-009

to allow the postsentence withdrawal of the guilty plea. Id. at ¶ 13; State v. Ayesta, 2015-

Ohio-1695, ¶ 8 (8th Dist.). When an alleged error underlying a motion to withdraw a guilty

plea is the ineffective assistance of counsel, the defendant must show (1) that his

counsel's performance was deficient and (2) that there is a reasonable probability that,

but for counsel's errors, he would not have pled guilty.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5800, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-paniagua-ohioctapp-2025.