State v. Williams

Citations

• 2025 Ohio 1345

Syllabus

GUILTY PLEA — COMPETENCE TO STAND TRIAL — STIPULATED REPORT — ARSON-OFFENDER REGISTRY — PLEA COLLOQUY — AGREED SENTENCE – DOUBLE JEOPARDY – ALLIED OFFENSES: The trial court did not err when it found defendant competent to stand trial and then accepted defendant's guilty pleas because defendant stipulated to the psychologist's competency report and the trial court based its competency determination on the stipulated report, which accounted for defendant's history, mental-health issues, and concerning behavior and concluded that defendant was competent to stand trial. Defendant's guilty pleas were not unknowingly, unintelligently, or involuntarily entered despite the trial court's misstatement regarding defendant's duty to register as an arson offender for life where defendant failed to demonstrate that the trial court's misstatement affected his decision to plead guilty. Where defendant forfeited the issue of allied offenses or double jeopardy when he failed to raise the issues to the trial court as it imposed the jointly-recommended sentences and defendant failed to argue plain error on appeal, defendant cannot show that his jointly-recommended sentences are not authorized by law.