OH9: IAC claim defendant pled guilty because of IAC in suppression hearing doesn’t show causal connection

“Mr. Bramos does not allege that his counsel’s statements to the trial court during the suppression hearing had any bearing on his decision to plead no contest more than two weeks later. We, therefore, conclude that Mr. Bramos has failed to establish that he received ineffective assistance of trial counsel.” State v. Bramos, 2020-Ohio-1169, 2020 Ohio App. LEXIS 1095 (9th Dist. Mar. 30, 2020).*

COA denied. Defendant fled with the package he’d just received (although his name wasn’t on it) and tossed it and his cell phone when police approached with an anticipatory search warrant. That was sufficient evidence of guilt. Black v. Robinson, 2020 U.S. App. LEXIS 9784 (6th Cir. Mar. 27, 2020).*

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