State v. Goodson, 2016 Ohio 1535

Goodson, a former employee at juvenile treatment facility Parmadale, was charged in two consolidated cases with multiple counts of sexual battery, unlawful sexual conduct with a minor, and interference with custody based on alleged sexual relationships with juvenile residents.
In Case No. CR-13-580768-A (2013 incidents) Goodson pleaded guilty to six counts of sexual battery (third-degree felonies), two counts of unlawful sexual conduct with a minor (third-degree felonies), and one misdemeanor; numerous other counts were nolled.
In Case No. CR-14-582561-A (2007–2008 incidents) Goodson pleaded guilty to three counts of unlawful sexual conduct with a minor (third-degree felonies); other counts were nolled.
At plea hearing the trial court informed Goodson of the possible monthly terms for a “high tier” third-degree felony (12, 18, 24, 30, 36, 42, 48, 54, or 60 months) but did not explain that those ranges applied per count or otherwise state her maximum exposure per count.
At sentencing the court imposed four years (48 months) for each third-degree felony count and ordered the 11 felony terms to run consecutively for a total sentence of 44 years; misdemeanor concurrent.
On appeal Goodson argued her plea was not knowingly, intelligently, and voluntarily entered because the court failed to inform her of the maximum penalty for each count; the appellate court vacated the pleas and sentences and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea was knowing, intelligent, and voluntary under Crim.R. 11(C)(2)(a)	State argued plea colloquy sufficiently conveyed exposure and rights waived.	Goodson argued court failed to inform her of maximum penalty per count so plea was not knowing and voluntary.	Court held trial court completely failed to comply with Crim.R. 11(C)(2)(a) regarding maximum penalty; plea vacated.
Whether court substantially complied with Crim.R. 11 for nonconstitutional advisements	State implied any minor deficiency was harmless or substantial compliance existed.	Goodson asserted lack of on-the-record understanding of maximum exposure made compliance deficient.	Court applied substantial-compliance framework and found no substantial compliance; complete failure meant no prejudice analysis required.
Whether sentence (44 years) was lawful and proportional under R.C. 2929.11	State maintained sentence was within statutory range and permissible.	Goodson argued sentence was excessive and inconsistent with similar offenders.	Court did not decide merits (moot) because plea vacated; noted apparent inconsistency but remanded for further proceedings.
Ineffective assistance / denial of motion to withdraw plea	State defended counsel performance and trial court’s denial.	Goodson claimed counsel misadvised and trial court abused discretion denying withdrawal.	Issues rendered moot by vacatur of plea and sentence; remanded for further proceedings.

Veney v. Ohio, 897 N.E.2d 621 (Ohio 2008) (strict compliance required for Crim.R.11 constitutional advisements; distinguishes constitutional vs. nonconstitutional requirements)
State v. Nero, 564 N.E.2d 474 (Ohio 1990) (substantial compliance standard for nonconstitutional Crim.R.11 advisements)
State v. Stewart, 364 N.E.2d 1163 (Ohio 1977) (defendant must subjectively understand plea implications for substantial compliance)
State v. Carter, 396 N.E.2d 757 (Ohio 1979) (discusses plea advisement standards)
State v. Caplinger, 664 N.E.2d 959 (Ohio Ct. App. 1996) (recognizes that appreciation of plea effects can cure trial-court advisory errors)
State v. Clark, 893 N.E.2d 462 (Ohio 2008) (distinguishes partial vs. complete noncompliance with Crim.R.11 and prescribes prejudice analysis when partial)
State v. Sarkozy, 881 N.E.2d 1224 (Ohio 2008) (complete failure to comply with Crim.R.11 mandates vacatur without prejudice showing)