State v. Griffin

Citations

• 2026 Ohio 925

Syllabus

Guilty plea; waiver of nonjurisdictional issues; App.R. 12; App.R. 16; separately assigned error; waive argument; hybrid sentence; no-contact order; community-control sanction; plain error; prejudice; invited error. Because appellant pled guilty, he waived any arguments related to the probable-cause finding by the juvenile court. Under App.R. 12(A) and 16(A), the court declined to consider appellant's argument regarding the validity of his plea because he did not separately assign this argument as error. Further, while the trial court improperly imposed hybrid sentences of a prison sentence and a no-contact order, which is a community-control sanction, appellant invited any error by accepting a plea agreement that included hybrid sentences. Moreover, appellant failed to demonstrate how he suffered any prejudice and therefore could not demonstrate plain error.