State v. Henson, 2022 Ohio 2828

David A. Henson was indicted on two counts of third-degree felony sexual battery and pled guilty to both counts pursuant to a plea agreement.
The trial court sentenced Henson to 60 months on one count and 48 months on the other, to be served consecutively for a total of nine years.
Henson appealed, arguing the trial court erred under Crim.R. 11(C)(2)(b) by failing to ensure he understood the effect of his guilty plea.
The trial court's plea colloquy informed Henson of the constitutional rights he waived, explained postrelease control and sex-offender registration, and the prosecutor recited the factual basis, which Henson confirmed.
The court relied on State v. Dangler (Ohio Supreme Court) for the standard that a defendant must show prejudice from a Crim.R. 11(C) error unless one of two exceptions applies (failure to explain constitutional rights or complete failure to comply).
The Twelfth District concluded the colloquy satisfied Crim.R. 11(C), found no complete failure or uncompensated constitutional-error exception, and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with Crim.R. 11(C)(2)(b) in informing and determining that Henson understood the effect of his guilty plea	The State: the court's colloquy (waivers, penalties, postrelease control, registration, factual basis) satisfied Crim.R. 11(C); any error did not prejudice Henson	Henson: the court did not adequately inform him of the "effect" of the plea (e.g., did not state the plea is a complete admission of guilt), so the plea was not knowing and intelligent	Affirmed: the court found Crim.R. 11(C) satisfied; no complete failure or exception invoked; plea was knowing, intelligent, and voluntary

State v. Dangler, 162 Ohio St.3d 1 (2020) (sets standard for reviewing Crim.R. 11(C) compliance and explains exceptions where prejudice need not be shown)