State v. Hall, 2022 Ohio 3455

Daryl A. Hall was charged in two Miami County municipal cases with violating a civil-protection order and agreed to plead no contest to those misdemeanors in exchange for dismissal of other cases.
While incarcerated and represented by counsel, Hall submitted inmate letters/handwritten motions (not served on the prosecutor) seeking dismissal and suppression and asserting he lacked notice of the civil protection-order hearing.
At the plea hearing Hall reiterated his notice complaint but admitted he had been served with the protection order itself.
The trial court accepted Hall’s no-contest pleas, found him guilty, and imposed (and suspended) 180-day jail terms, two years’ community control, $25 fines and court costs in each case.
Hall appealed, arguing the court erred by accepting pleas before ruling on his pending motions and failed to adequately inquire into his due-process claim about the protection order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in accepting no-contest pleas while motions to dismiss/suppress were pending	A guilty/no-contest plea renders pending motions moot; no error in accepting plea	Court should have ruled on pending motions before accepting pleas	Pleas rendered the motions moot; no error in accepting the no-contest pleas
Whether defendant may collaterally attack the validity of the civil protection order (lack of notice) in the criminal prosecution for violating it	Collateral attack is improper; order remained in effect and Hall was served; plea admissions waive the challenge	Lack of notice made the protection order invalid, so Hall could not lawfully be convicted of violating it	Collateral attack not permitted in the criminal violation case; no-contest pleas admitted the alleged facts and waived sufficiency challenges

None — this opinion relied on unpublished/appellate slip decisions and state statutes; it did not cite authorities having official reporter citations.