State v. Diefenbacher, 2013 Ohio 4428

Defendant Jody Shane Diefenbacher was indicted on multiple drug- and theft-related felonies, including illegal manufacture of drugs charged as a first-degree felony.
A jury convicted him on two counts and deadlocked on the manufacturing and chemical-assembly charges; the court declared a mistrial on the deadlocked counts.
Parties reached a plea agreement: the assembly/chemicals count would merge into the manufacture count and the manufacture charge would be reduced from a first-degree to a second-degree felony; Diefenbacher agreed to plead guilty to the reduced charge.
At the plea hearing, confusion arose about whether the plea was to a first- or second-degree felony; the court initially misstated mandatory minimums for a first-degree offense, then reconvened and advised the defendant of the second-degree range (maximum 8 years, mandatory imprisonment with a three-year minimum).
Diefenbacher pled guilty, was sentenced to six years on the manufacturing count (concurrent with other terms), and later appealed, arguing his plea was not knowing, intelligent, and voluntary because he believed the mandatory term was three years rather than six.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea was knowing, intelligent, voluntary under Crim.R. 11	State: court substantially complied with Crim.R. 11(C)(2)(a); defendant understood minimum and maximum penalties	Diefenbacher: confusion at colloquy left him believing he would receive a mandatory three-year sentence, so plea was involuntary	Court: substantial compliance satisfied; defendant understood implications; plea valid

State v. Engle, 74 Ohio St.3d 525 (1996) (plea must be knowing, intelligent, and voluntary)
State v. Nero, 56 Ohio St.3d 106 (1990) (definition of substantial compliance with Crim.R. 11)
State v. Veney, 120 Ohio St.3d 176 (2008) (distinguishes strict vs. substantial compliance and requires prejudice showing for nonconstitutional omissions)