State v. Slaughter

2026 Ohio 377
CourtOhio Court of Appeals
DecidedFebruary 6, 2026
Docket30589
StatusPublished

This text of 2026 Ohio 377 (State v. Slaughter) 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. Slaughter, 2026 Ohio 377 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Slaughter, 2026-Ohio-377.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

STATE OF OHIO : : C.A. No. 30589 Appellee : : Trial Court Case No. 2024 CR 02142 v. : : (Criminal Appeal from Common Pleas ANDREW L. SLAUGHTER III : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on February 6, 2026, the judgment of

the trial court is affirmed in part, reversed in part, and remanded for further proceedings in

accordance with the opinion.

Costs to be paid as follows: 50% by appellee and 50% by appellant.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

LEWIS, P.J., and HUFFMAN, J., concur. OPINION MONTGOMERY C.A. No. 30589

CHIMA R. EKEH, Attorney for Appellant SARAH H. CHANEY, Attorney for Appellee

TUCKER, J.

{¶ 1} Andrew L. Slaughter III appeals from his conviction following a guilty plea to

aggravated drug possession, a third-degree felony.

{¶ 2} Slaughter contends that the trial court erred in accepting his plea because it was

not knowingly, intelligently, and voluntarily entered. He also challenges the trial court’s

overruling of a pre-sentence motion to withdraw the plea. Finally, he claims his sentence

was unauthorized by law insofar as the trial court disapproved shock incarceration or

placement in an intensive program prison.

{¶ 3} We conclude that Slaughter’s plea was valid under Crim.R. 11 and that the trial

court did not abuse its discretion by overruling his motion to vacate it. We agree, however,

that his sentence was not authorized by law insofar as the trial court failed to give factual

reasons for disapproving shock incarceration or placement in an intensive program prison.

That omission rendered the trial court’s disapproval contrary to law under

R.C. 2953.08(G)(2)(b). Accordingly, the trial court’s judgment is affirmed in part and

reversed in part, and the case is remanded for further proceedings.

I. Background

{¶ 4} A grand jury indicted Slaughter on a charge of aggravated drug possession as

a second-degree felony. He later agreed to plead guilty to the offense as a third-degree

felony. The parties also agreed to a prison sentence of one to two years. During a February

21, 2025 plea hearing, defense counsel represented that the trial court had agreed to impose

2 a one-year sentence if Slaughter cooperated with pretrial services and did not commit any

new offenses. Following a Crim.R. 11 colloquy, the trial accepted the plea and made a

finding of guilt. Due to the agreed sentence, it declined to order a presentence investigation

and set the matter for sentencing on March 3, 2025.

{¶ 5} One week later, Slaughter sought to withdraw his plea. His written motion

asserted that he had been “thinking about this case” and that he had “made a mistake by

entering a plea.” He stated that he “felt he was forced to make a decision before he was

sure” about pleading guilty. The trial court held an August 4, 2025 hearing on the motion,

but Slaughter declined to testify or present any evidence. Defense counsel simply argued

that withdrawal was necessary to prevent a manifest injustice for two reasons: (1) Slaughter

felt pressured to plead guilty in order to have a capias for his arrest withdrawn; and (2) he

did not know that the plea included a prison sentence of one to two years. The trial court

found these arguments unpersuasive and overruled the motion.

{¶ 6} Slaughter subsequently appeared for sentencing on August 11, 2025. He

received a one-year prison term. The trial court noted that he was eligible for shock

incarceration or an intensive program prison but disapproved such placement “based on the

purposes and principles of sentencing, the seriousness and recidivism factors, and the [plea]

agreement.” Slaughter timely appealed, advancing three assignments of error.

II. Analysis

{¶ 7} The first assignment of error states:

APPELLANT’S PLEA WAS NOT ENTERED KNOWINGLY,

INTELLIGENTLY, AND/OR VOLUNTARILY.

{¶ 8} Slaughter acknowledges that the trial court conducted a plea hearing in

compliance with Crim.R. 11. He nevertheless argues that his guilty plea was invalid for three

3 reasons: (1) he felt compelled to enter the plea in order to have a capias withdrawn; (2) the

plea form stated that he was eligible for community control whereas the trial court orally

advised him that he was ineligible; and (3) his attorney failed to tell him that a jointly

recommended sentence generally was not reviewable on appeal or that he would not receive

judicial release.

{¶ 9} Upon review, we find the foregoing arguments to be unpersuasive. On February

7, 2025, the trial court issued a capias for Slaughter’s arrest based on his failure to comply

with a bond condition. Without being arrested, Slaughter then appeared for the plea hearing

on February 21, 2025. The only discussion of the capias came from defense counsel. At the

outset of the hearing, defense counsel addressed the trial court and stated: “Your Honor had

indicated that [if] Mr. Slaughter did enter a plea that you would give a 12-month sentence

minus credit for time served. Also, Mr. Slaughter has an outstanding capias from pretrial

services. And you had indicated Mr. Slaughter can’t then enter a plea if he immediately went

to pre-trial services, but that the warrant would be lifted.”

{¶ 10} We are unsure what defense counsel meant about Slaughter being unable to

enter a plea if he went to pretrial services. In any event, the trial court appears to have

agreed to withdraw the capias, and it did so after the hearing. It is unclear from defense

counsel’s comment, however, that the trial court conditioned withdrawal of the capias on a

guilty plea. But even if it did, Slaughter has not established that the capias issue negated

the knowing, intelligent, and voluntary nature of his plea.

{¶ 11} As for community control, the plea form correctly indicated that Slaughter was

eligible. Contrary to his argument, the trial court did not advise him otherwise during the plea

hearing. Due to the agreed sentence, it stated only that it would not consider imposing

community control. Finally, the record does not reveal what, if anything, defense counsel

4 told Slaughter about the reviewability of an agreed sentence or the possibility of judicial

release. Because any discussion between Slaughter and his attorney occurred outside of

the record, he cannot use it on direct appeal to establish ineffective assistance affecting the

validity of his plea. State v. Cole, 2025-Ohio-675, ¶ 7 (2d Dist.). Accordingly, the first

assignment of error is overruled.

{¶ 12} The second assignment of error states:

THE TRIAL COURT ERRED IN DENYING APPELLANT’S MOTION TO

WITHDRAW HIS GUILTY PLEA.

{¶ 13} Slaughter contends the trial court abused its discretion by not permitting him

to withdraw his guilty plea. He analyzes the issue under the standards applicable to pre-

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Bluebook (online)
2026 Ohio 377, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-slaughter-ohioctapp-2026.