In motion to withdraw no contest pleas in convictions in 2000, 2003 and 2005 after defendant was issued a notice to appear for immigration removal proceedings, denial of motion was not error where untimely since defendant was aware of the immigration consequences for at least two years before filing his motion to withdraw and he did not provide any explanation for his delay, R.C. 2943.031.
State v. Reyes. 2016-Ohio-2771