State v. Knight

Citations

• 2021 Ohio 3674

Syllabus

Crim.R. 11 guilty plea knowingly, intelligently, and voluntarily constitutional guarantees waiving constitutional rights mental illness. Due process requires that a defendant's plea be made knowingly, intelligently, and voluntarily otherwise, the defendant's plea is invalid. When a trial court fails to explain the constitutional rights that a defendant waives by pleading guilty or no contest, we presume that the plea was entered involuntarily and unknowingly, and no showing of prejudice is required. To aid our analysis, the Ohio Supreme Court in State v. Dangler, 162 Ohio St.3d 1, 2020-Ohio-2765, 164 N.E.3d 286, provided a three-question test namely: (1) has the trial court complied with the relevant provision of [Crim.R. 11]? (2) if the [trial] court has not complied fully with the rule, is the purported failure of a type that excuses a defendant from the burden of demonstrating prejudice? and (3) if a showing of prejudice is required, has the defendant met that burden? Appellant raises an assortment of challenges to the trial court's review of the nature of the charges, the maximum penalties involved, and the effect of his pleas as required by Crim.R. 11(C)(2)(a) and (b). Because appellant's challenges all involve parts of the rule that relate to nonconstitutional issues, appellant must affirmatively show prejudice to invalidate his plea where the trial court fails to comply fully with Crim.R. 11(C)(2)(a)-(b). Dangler ¶ 14. Our review of the transcript of the sentencing hearing reveals a textbook compliance with these requirements. Appellant asserts that his declining mental and physical condition impacted his guilty pleas. Specifically, that his schizoaffective disorder, frequent hallucinations, hearing voices, and seeing ghosts, along with his 58-pound weight loss, possibly due to a staph infection, rendered his pleas not knowingly, voluntarily, and intelligently made. However, it is well established, that a defendant does not lack mental capacity to enter a ple