State v. Philpot

2022 Ohio 1499
CourtOhio Court of Appeals
DecidedMay 5, 2022
Docket110828
StatusPublished
Cited by5 cases

This text of 2022 Ohio 1499 (State v. Philpot) 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. Philpot, 2022 Ohio 1499 (Ohio Ct. App. 2022).

Opinion

[Cite as State v. Philpot, 2022-Ohio-1499.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 110828 v. :

ADOLPHUS PHILPOT, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: May 5, 2022

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-21-658357-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Kristen L. Hatcher, Assistant Prosecuting Attorney, for appellee.

Mary Catherine Corrigan and Britt Newman, for appellant.

MARY J. BOYLE, J.:

Defendant-appellant, Adolphus Philpot (“Philpot”), appeals his guilty

plea and sentence for felonious assault and having weapons while under disability

(“HWWUD”). For the reasons set forth below, we affirm the trial court’s judgment. In April 2021, Philpot was charged with two counts of felonious

assault (Counts 1 and 2) and one count of HWWUD (Count 3).1 Each of the felonious

assault counts carried one- and three-year firearm specifications. On the day of trial,

July 1, 2021, plaintiff-appellee, the state of Ohio, offered Philpot two plea options.

The trial court gave Philpot additional time, off the record, to discuss the options

before proceeding with trial.

When the matter resumed on the record, the state explained that

there was an oversight in the plea agreement regarding the HWWUD count, which

was not included in either plea option. Defense counsel for Philpot explained to the

court that he confirmed with the state that Philpot accepted option 1, which was

pleading guilty to felonious assault (Count 2), with a one-year firearm specification,

and the remaining specification and all other counts would be dismissed. Then,

before the matter was to resume on the record again, he was advised that an

additional count was added to the plea, the HWWUD. The trial court stated:

Well, let me say this; I almost never get involved in plea bargaining, and I will acknowledge that any time you’re admitting to a crime, any crime, there is — it’s a disadvantage to you. You have a record of a felony conviction. So acknowledging that and generally being reluctant to insert myself into the plea bargaining, what if I say this; I don’t know if Mr. Philpot has a plea bargain what his sentence will be — sentences, there’s more than one charge, but I will say if he pled to a felonious assault that had a firearm spec prison is mandatory. What if there’s an understanding that if he is sent to prison on a weapons under disability that it would be; A, equal to or less time than on the felonious and; B, concurrent?

1 Philpot’s bond was revoked on June 24, 2021, after evidence at a hearing revealed that Philpot violated the conditions of his bond by calling the victim and offering money to drop the accusations against him. (Tr. 38, July 1, 2021.)

The trial court then gave Philpot time to discuss the matter with

defense counsel off the record. When the matter resumed on the record, defense

counsel indicated that Philpot accepted the plea agreement with the addition of the

HWWUD count. The trial court then proceeded with the Crim.R. 11 plea colloquy,

and Philpot pled guilty to an amended count of felonious assault (Count 2), with a

one-year firearm specification attached, and HWWUD (Count 3). The remaining

count and firearm specifications were dismissed. At the court’s suggestion, both

parties agreed for the court to use a previous presentence investigation report from

2015 for Philpot.

On July 23, 2021, Philpot filed a presentence motion to withdraw his

guilty plea. The trial court held a hearing on the matter on August 5, 2021. Philpot

argued that he felt coerced to accept the plea agreement because the state changed

the plea after he communicated to the state that he would accept it. As a result,

Philpot claimed he was in a “very pressured situation” and did not have ample time

to do a “cost-benefit analysis.” The state acknowledged that there was some

confusion regarding the plea at the time, but Philpot did proceed through the

Crim.R. 11 colloquy without raising that concern and the trial court complied with

Crim.R. 11. The court denied the motion, finding that while “the question of what to

do about the weapons under disability charge was apparently not resolved between

the parties before we went on the record that hearing, [the issue] was adequately addressed during the change of plea hearing.” As a result, the court found that “the

guilty plea was knowingly and voluntarily made.”

Before the court could proceed directly to sentencing, Philpot

indicated he was unsatisfied with defense counsel’s representation and would like

new assigned counsel. Philpot stated that he was dissatisfied because he just

received discovery. When the trial court inquired further, Philpot stated that

defense counsel had advised what he learned but did not give him actual copies of

documents until the day of the hearing. Philpot also stated that he felt rushed in

taking the plea but did acknowledge that he had a thorough conversation with the

court about his plea and sentence. The trial court stated that the criminal rules were

followed, and Philpot was given the proper advisements. The court further stated to

Philpot that it did not “remember you ever telling me you didn’t understand what

was going on or that you were too rushed[.]” (Tr. 95, Aug. 5, 2021.). After giving

defense counsel an opportunity to speak, the trial court denied the motion.

The matter then proceeded to sentencing on August 31, 2021. The

trial court sentenced Philpot to one year in prison on the firearm specification, to be

served prior and consecutive to the felonious assault charge (Count 2). The trial

court sentenced Philpot to an indefinite sentence of three to four-and-one-half years

pursuant to the Reagan Tokes Law on felonious assault, a second-degree felony. The

trial court imposed a sentence of 24 months on HWWUD (Count 3), a third-degree

felony, to be served concurrently with the sentence on Count 2. Philpot now appeals, raising the following four assignments of error

for our review, which shall be discussed together where appropriate.

First Assignment of Error: The trial court abused its discretion when it failed to grant [Philpot’s] pre-sentence motion to withdraw plea.

Second Assignment of Error: The trial court violated the [Philpot’s] Sixth Amendment rights to the effective assistance of counsel when it failed to grant a substitution of assigned counsel.

Third Assignment of Error: Trial counsel was ineffective for failing to object to the imposition of the Reagan Tokes tail.

Fourth Assignment of Error: The trial court erred by imposing an unconstitutional sentence pursuant to the Reagan Tokes Act.

Presentence Motion to Withdraw Plea

In the first assignment of error, Philpot argues the trial court abused

its discretion when it denied his presentence motion to withdraw his guilty plea.

Under Crim.R. 32.1, a criminal defendant may move to withdraw a

guilty plea before sentence is imposed. Generally, “a presentence motion to

withdraw a guilty plea should be freely and liberally granted.” State v. Xie, 62 Ohio

St.3d 521, 527, 584 N.E.2d 715 (1992). A defendant, however, “does not have an

absolute right to withdraw a plea prior to sentencing.” Id. at paragraph one of the

syllabus.

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2022 Ohio 1499, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-philpot-ohioctapp-2022.