State v. Cuyler

Citations

• 2025 Ohio 4461

Syllabus

Plea colloquy; delayed appeal; complete admission of guilt; Crim.R. 11(B)(1); Crim.R. 11(C)(2)(a); Crim.R. 11(C)(2)(b). Judgment reversed and case remanded. Appellant Cuyler's guilty plea was not knowing, intelligent, and voluntary due to the trial court's complete failure to comply with a portion of Crim.R. 11(C). The trial court did not inform Cuyler that his guilty plea would constitute a complete admission of guilt and made references to Cuyler taking only some responsibility for the charges against him, and not necessarily what the State was accusing him of doing. This introduced confusion into the proceedings, potentially inviting Cuyler to view his plea as less than a complete admission of guilt. It was therefore not obvious from the context of the plea colloquy that Cuyler understood the effect of his plea of guilty. There was a complete failure to comply with a portion of Crim.R. 11(C), which relieved Cuyler of any burden to demonstrate prejudice and required vacating his guilty plea.