State v. Dowdell
2012 Ohio 1326
Ohio Ct. App.2012Background
- Dowdell was indicted in Summit County on numerous charges, including engaging in a pattern of corrupt activity and multiple counts of breaking and entering, theft of drugs, possessing criminal tools, and possession of drugs.
- Dowdell pleaded guilty on November 24, 2010; the trial court sentenced him to a total of ten years' imprisonment and dismissed the remaining charges.
- A delayed appeal was granted on May 18, 2011, allowing Dowdell to pursue an appeal from the judgment of conviction.
- Counsel filed an Anders brief in August 2011 asserting no meritorious assignments of error; Dowdell filed a pro se response alleging his plea was not knowingly, voluntarily, and intelligently entered due to psychotropic medications.
- The issue presented concerns whether Dowdell’s plea was valid given allegations that he was on multiple medications and whether the court should have ordered a mental health evaluation prior to accepting the plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the plea was knowingly, voluntarily, and intelligently entered. | State argues the plea was valid; the trial court engaged in a thorough colloquy and there is no record showing the court knew of medications. | Dowdell contends that his medications undermined his ability to understand and waives without proper Crim.R. 11 procedures. | Plea valid; no prejudice shown; transcript shows understanding; no grounds for reversal on this issue. |
| Whether the trial court was required to order a mental health evaluation before accepting the plea. | State maintains no such requirement; substantial compliance with Crim.R. 11 suffices under the circumstances. | Dowdell argues the court should have ordered an evaluation given his medications. | No error; trial court's proceedings were proper; no need for an evaluation given the record and dialogue. |
Key Cases Cited
- State v. Engle, 74 Ohio St.3d 525 (Ohio 1996) (plea must be knowingly, voluntarily, and intelligently entered)
- State v. Meredith, 2011-Ohio-1517 (9th Dist. No. 25198, 2011) (substantial compliance for non-constitutional Crim.R. 11 notifications)
- Veney v. State, 120 Ohio St.3d 176 (Ohio 2008) (constitutional rights require strict compliance; other notifications rely on substantial compliance)
- State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (totality of the circumstances governs understanding of plea and waivers)
- State v. Eakin, 2002-Ohio-4713 (5th Dist. No. 01-CA-00087, 2002) (trial court may be required to assess problem but not necessarily obtain medical confirmation)