State v. Dangler (Slip Opinion), 2020 Ohio 2765

Defendant Brad Dangler was indicted for rape (1st-degree felony); charge amended to sexual battery (3rd-degree felony) and he pled no contest as part of a negotiated 36‑month sentence.
At the plea hearing the trial court told Dangler he would be required to register as a Tier III sex offender for life and Dangler said he understood; the court later at sentencing detailed registration, in‑person verification, and possible prosecution for noncompliance.
Dangler appealed, arguing the plea was not knowing and voluntary because the trial court failed at the plea hearing to explain the full range of penalties tied to R.C. Chapter 2950 (registration specifics, residency restrictions, community notification), and thus Crim.R. 11(C)(2)(a) was not satisfied.
The Sixth District vacated the plea, holding that failure to enumerate those separate registration/community/residency elements was a complete Crim.R. 11(C)(2)(a) noncompliance that relieved Dangler of proving prejudice; it certified conflict with other districts.
The Supreme Court of Ohio accepted the certified question and held that informing a defendant he is subject to the sex‑offender‑registration scheme is not a complete failure to comply with Crim.R. 11(C)(2)(a); a defendant must show prejudice (i.e., he would not have pleaded but for the omission) to vacate a plea, and Dangler did not do so.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court’s failure at plea hearing to explain all R.C. Chapter 2950 penalties (registration details, community notification, residency restrictions) constitutes a complete failure under Crim.R. 11(C)(2)(a) excusing a showing of prejudice	Dangler: omission of those specifics is a complete noncompliance so prejudice need not be shown	State: telling defendant he would be a Tier III registrant and subject to lifetime registration constitutes substantial compliance; prejudice must be shown	Court: Not a complete failure. Advising the defendant he was subject to the registration scheme avoided complete noncompliance; prejudice is required
Whether Dangler satisfied the prejudice test (would not have pled absent fuller advisement)	Dangler: challenges on appeal amount to demonstrating he would not have pled	State: record contains no indication Dangler would have rejected the plea absent fuller advisement; no prejudice shown	Court: Prejudice must be shown on the record; Dangler did not demonstrate prejudice, so plea stands

State v. Williams, 129 Ohio St.3d 344 (2011) (analyzed aggregate punitive effect of S.B. 10/Adam Walsh changes for retroactivity analysis)
State v. Sarkozy, 117 Ohio St.3d 86 (2008) (complete failure to inform of postrelease control in plea colloquy excused prejudice requirement)
State v. Clark, 119 Ohio St.3d 239 (2008) (distinguishes constitutional advisals that trigger presumed prejudice from nonconstitutional advisals)
State v. Veney, 120 Ohio St.3d 176 (2008) (same; rule on constitutional rights advisals)
State v. Nero, 56 Ohio St.3d 106 (1990) (prejudice test for nonconstitutional Crim.R. 11 omissions)
Parke v. Raley, 506 U.S. 20 (1992) (guilty plea must be knowing, intelligent, and voluntary)
State v. Stone, 43 Ohio St.2d 163 (1975) (Crim.R. 11 ensures an adequate record that the plea was knowing and voluntary)