State v. Carey, 2011 Ohio 1998

Carey was indicted in Union County on 72 theft-related counts for acts in 2008; 54 counts remained after dismissals and amended charges.
On the day trial was set to begin, Carey changed her plea from not guilty to guilty on all remaining counts pursuant to a written plea agreement, with a 10-year sentencing recommendation.
Crim.R. 11 colloquy was conducted; the court informed Carey of potential sentences and ensured she understood rights and options.
Carey initially denied participation but ultimately admitted guilt to the acts described in the statement of facts and pleaded guilty to all 54 counts.
The trial court accepted the pleas, ordered presentence investigation, and scheduled sentencing; Carey was sentenced to a total of 10 years with restitution of $32,604.31.
Carey appealed, challenging (1) the validity of the guilty plea given statements of innocence and (2) the need for an enhanced Alford inquiry; the appellate court affirmed below.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Carey’s plea was knowing, voluntary, and intelligent given protestations of innocence.	Carey asserted the plea was not knowing or voluntary because of ongoing innocence.	Carey argued her statements of innocence warranted an Alford-type inquiry.	Plea not an Alford plea; defenses acknowledged guilt after initial denial. The plea was knowing and voluntary.
Whether the trial court was required to conduct a heightened Alford inquiry.	Carey claimed the court failed to perform a proper Alford inquiry.	No heightened inquiry was required because the plea was not an Alford plea and Carey repeatedly admitted guilt.	moot since plea was not Alford; no enhanced inquiry required.

North Carolina v. Alford, 400 U.S. 25 (U.S. Supreme Court 1971) (permits accepting guilty pleas while defendant maintains innocence under certain conditions)
State v. Piacella, 27 Ohio St.2d 92, 271 N.E.2d 852 (Ohio 1971) (development of Alford-type considerations in Ohio)
State v. Padgett, 67 Ohio App.3d 332, 586 N.E.2d 1194 (Ohio App. 1990) (requirement that pleas with protestations of innocence be scrutinized for knowing waiver)
In re Kirby, 101 Ohio St.3d 312, 804 N.E.2d 476 (Ohio 2004) (discussion of when Alford reasoning may apply in Ohio)
State v. Vogelsong, 2007-Ohio-4935 (Ohio App. 3d 2007) (Alford-like considerations in Ohio; remedy where innocence asserted)
State v. Schmidt, 2010-Ohio-4809 (Ohio App. 3d 2010) (expanded discussion of Alford-like pleas in Third District)