State v. Adkins, 2015 Ohio 4605

Three-week-old infant treated for extensive injuries: thirteen acute rib fractures, facial bruising, and a liver laceration.
Adkins was initially indicted on Felonious Assault and Child Endangering; she moved to suppress statements made during police interrogation and the motion was denied.
A plea agreement: Adkins would enter an Alford plea to Endangering Children and the Felonious Assault count would be dismissed; a new information was filed charging Endangering Children.
Adkins filed a waiver of indictment, entered an Alford (protestation-of-innocence) plea, and was sentenced to four years’ imprisonment.
Adkins appealed, arguing (1) the trial court erred in denying her suppression motion and (2) the court failed to satisfy Crim.R. 11 when accepting her Alford plea.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Adkins)	Held
Whether denial of suppression motion was reviewable after plea	Suppression ruling moot/waived by guilty/Alford plea	Trial court erred in overruling suppression motion; statements should be suppressed	Waived by Alford plea; suppression error not preserved and no prejudice because conviction was by plea
Whether trial court complied with Crim.R. 11 and properly accepted Alford plea	Court conducted full Crim.R.11 colloquy, reviewed evidence, and ensured plea was knowingly, intelligently made	Court failed to make the additional required inquiry to confirm Adkins made a rational decision to plead despite protestations of innocence	Court complied with Crim.R.11 and made sufficient inquiry; State’s strong evidence and defendant’s informed choice supported acceptance of Alford plea

North Carolina v. Alford, 400 U.S. 25 (1970) (permits a guilty plea despite protestations of innocence when defendant knowingly accepts conviction exposure to avoid greater penalty)
State v. Elliott, 86 Ohio App.3d 792 (12th Dist. 1993) (guilty plea waives appellate review of alleged trial-court errors in suppression rulings)