State v. Baker, 2021 Ohio 4544

Rondey Baker was indicted for attempted murder and two counts of felonious assault, each with repeat-violent-offender specifications; he pled guilty to attempted murder in exchange for dismissal of the other counts and specifications.
The plea was accepted on January 16, 2021; on March 3, 2021 the court imposed a mandatory 10–15 year prison term.
The trial court did not advise Baker, before accepting his plea, of the presumption of enrollment in the statewide violent-offender database ("Sierah's Law") or his right to move to rebut that presumption under R.C. 2903.42(A)(1)(a).
Sierah's Law (R.C. 2903.41–2903.44) creates a violent-offender database and a presumption that qualifying offenders must enroll and perform duties (annual in-person re-enrollment, change-of-address notifications) for ten years; those classified under R.C. 2903.41(A)(1) must receive the statutory advisements before sentencing.
The trial court also failed at sentencing to provide the written notice/read-and-sign form required by R.C. 2903.42(C) when no rebuttal motion had been filed.
On appeal Baker raised two assignments: (1) his plea was not knowing/voluntary because the court failed to advise him of Sierah's Law during the plea colloquy; and (2) his sentence is void because the court failed to give the mandatory pre-sentencing advisements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to advise of violent-offender enrollment during plea colloquy invalidates guilty plea	State: Advising on Sierah's Law is collateral; Crim.R.11 does not require the court to give such advisals before accepting a plea	Baker: Plea was not knowingly, intelligently, voluntarily made because court failed to provide required R.C. 2903.42(A)(1)(a) advisals at plea	Overruled Baker's first assignment — plea remains valid; registration duties are collateral and need not be explained under Crim.R.11 before plea
Whether sentence is void for failure to provide mandatory pre-sentencing advisals and the notice/read-and-sign form	State: (implicitly) sentence should stand despite omission / error not jurisdictional	Baker: Sentence void because statute required advisals before sentencing, and omission deprived him of opportunity to move to rebut	Sustained Baker's second assignment — sentence vacated and remanded for the mandatory R.C. 2903.42 advisals and resentencing

State v. Engle, 74 Ohio St.3d 525 (establishes that guilty pleas must be made knowingly, intelligently, and voluntarily)
State v. Ferguson, 120 Ohio St.3d 7 (registration statutes are collateral consequences, not additional punishment)
State v. Marcum, 146 Ohio St.3d 516 (explains appellate standard of review for felony sentences under R.C. 2953.08)