State v. Gooden, 2021 Ohio 1192

Gooden was indicted on 45 counts for a string of burglaries and robberies (July–Oct. 2018); he initially pleaded not guilty.
After a jury was empaneled, Gooden agreed to plead guilty to an amended 19-count indictment (including R.C. 2923.32 pattern of corrupt activity, multiple aggravated robberies with two 1‑year firearm specifications, burglaries, weapons-under-disability counts, felonious assault, and receiving stolen property).
At the plea hearing the trial court advised Gooden of constitutional rights he waived, reviewed the felony-level charges, discussed potential maximum penalties (the court and counsel referenced an aggregate in the 140–157 year range), and accepted a joint recommendation of 20–30 years.
The trial court found the plea knowing, intelligent, and voluntary, accepted it, and later sentenced Gooden to an aggregate 29 years’ imprisonment.
On appeal Gooden argued his plea was not knowing, intelligent, and voluntary because (1) the court incorrectly stated all firearm specifications must run consecutively, and (2) the court failed to advise him of the true maximum aggregate sentence; he did not show he was prejudiced or would have pleaded differently.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court misstated that all firearm specifications must run consecutively	State: R.C. 2929.14(B)(1)(g) exception applies only to specs from the same act/transaction; where offenses are separate, R.C. 2929.14(C)(1)(a) mandates consecutive firearm terms	Gooden: Court misinformed him that all firearm specs must run consecutively (argues only two highest specs must be consecutive under R.C. 2929.14(B)(1)(g))	Court: Rejected Gooden; his robberies were separate transactions, so B(1)(g) inapplicable and consecutive service of all firearm specs was permissible under R.C. 2929.14(C)(1)(a)
Whether the trial court failed to inform defendant of the maximum penalty required under Crim.R. 11(C)(2)(a)	State: Crim.R.11 requires advising the maximum penalty for each offense, not the full cumulative aggregate; trial court substantially complied and defendant was not prejudiced	Gooden: Court did not fully advise him of the potential aggregate maximum (claimed court "stopped counting" at ~150 years)	Court: Crim.R.11 requires advising single-offense maximums; no requirement to state cumulative total; Gooden showed no prejudice and plea was knowing, intelligent, and voluntary

State v. Engle, 74 Ohio St.3d 525 (plea must be knowing, intelligent, and voluntary)
State v. Nero, 56 Ohio St.3d 106 (Crim.R.11 purpose and substantial-compliance standard)
State v. Ballard, 66 Ohio St.2d 473 (Crim.R.11 ensures voluntary, informed plea)
State v. Stewart, 51 Ohio St.2d 86 (consider totality of circumstances in plea review)
State v. Griggs, 103 Ohio St.3d 85 (strict vs. substantial compliance; prejudice requirement for nonconstitutional errors)
State v. Johnson, 40 Ohio St.3d 130 (Crim.R.11 "maximum penalty" refers to single-offense maximum)
State v. Saxon, 109 Ohio St.3d 176 (same)