State v. Halderman
2025 Ohio 2253
| Ohio Ct. App. | 2025Background
- Shaun W. Halderman was charged with three counts of unlawful sexual conduct with a minor under R.C. 2907.04, all first-degree misdemeanors due to his age (18) and the minor victim’s age.
- Halderman pled guilty to one count in exchange for the dismissal of the other two.
- At the plea hearing, the trial court described the charge and potential penalty (up to six months in jail and a $1,000 fine) but did not explain constitutional rights or the effect of the plea in detail.
- Halderman was sentenced to 180 days in jail (90 suspended) and classified as a Tier I sex offender.
- On appeal, Halderman argued that his plea was involuntary due to the court’s failure to comply with Criminal Rule 11(C)(2) and 11(D).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Crim.R. 11(C)(2) & 11(D) | Halderman: Court failed to advise of constitutional rights and plea effects per rules. | State: Rules only apply to serious offenses or felonies. | Crim.R. 11(C)(2) & 11(D) do not apply to misdemeanors like this; no advisement required. |
| Court's Obligation Under Crim.R. 11(E) | Halderman: Failure to inform of plea’s constitutional waiver invalidates plea. | State: Only needed to state effect (admission of guilt) for petty offenses. | Court only needed to state that guilty plea = full admission; did not affect plea’s validity. |
| Notice of Sex-Offender Registration | Halderman: Court failure to mention requirement invalidates plea. | State: Not required for petty offenses; not in Crim.R. 11(E). | No requirement to advise of sex-offender registration under Crim.R. 11(E). |
| Relevance/Distinguishability of Hawkins | Halderman: Hawkins case required notice of sex-offender status. | State: Hawkins involved felonies; different rule applied. | Hawkins distinguished; only applies to felonies and Crim.R. 11(C). |
Key Cases Cited
- State v. Ballard, 66 Ohio St.2d 473 (Ohio 1981) (outlining plea colloquy requirements for felony cases)
- State v. Jones, 2007-Ohio-6093 (Ohio Ct. App.) (explaining court obligations in accepting misdemeanor pleas)
- State v. Hawkins, 2013-Ohio-2572 (Ohio Ct. App.) (Crim.R. 11(C) plea advisement requirements for felonies)