State v. Irvin, 2013 Ohio 5209

Donte Irvin, an inmate at Warren Correctional Institution, was indicted for one count of assault (a fifth-degree felony) for allegedly causing physical harm to a corrections officer on June 1, 2012.
Irvin pled guilty on February 6, 2013; the trial court advised him of rights forfeited by a guilty plea and accepted the plea.
The court sentenced Irvin to six months imprisonment to run consecutive to his existing sentence.
On appeal, Irvin argued the trial court failed to determine he understood the nature of the charge and the status of his indictment, and therefore his plea was not knowing, intelligent, and voluntary.
The appellate court reviewed whether the Crim.R. 11(C)(2)(a) colloquy substantially complied with requirements for nonconstitutional advisements (defendant’s understanding of the nature of the charge) and whether prejudice was shown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court satisfied Crim.R. 11(C)(2)(a) that the defendant understood the nature of the charge	The State argued the court substantially complied: court named the offense and degree, the plea form identified the statute and felony degree, and defendant confirmed understanding and signed the form.	Irvin argued the court failed to determine he understood the nature of the charge and the status of the indictment, so the plea was invalid.	Court held there was substantial compliance with Crim.R. 11(C)(2)(a); no prejudice shown; plea valid.
Whether failure to inform of additional charges (if any) invalidates plea	N/A (State noted there were no other charges).	Irvin claimed omission of additional charges was error.	Court held the indictment contained a single count; there were no additional charges, so no error.

State v. Veney, 120 Ohio St.3d 176 (discussing Crim.R. 11 and distinctions between constitutional and nonconstitutional advisements)
State v. Engle, 74 Ohio St.3d 525 (noting pleas must be knowing, intelligent, and voluntary)