State v. Jones, 2012 Ohio 2512

Jones was charged with multiple offenses including aggravated burglary, aggravated robbery, and weapon under disability.
On the day set for trial, Jones pleaded guilty to one burglary, one robbery, and one weapon-under-disability count and the indictment was amended accordingly.
During the plea colloquy, Jones stated innocence and fear, and acknowledged uncertainty about the evidence before the court accepted the plea.
The court referred Jones for a presentence report and continued to sentencing.
Jones later moved to withdraw the plea before sentencing, arguing lack of a factual basis and his protestations of innocence.
The trial court denied the motion and sentenced Jones to an aggregate eight-year term; on appeal, the conviction and sentence were challenged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying the presentence motion to withdraw the plea.	Jones argues lack of factual basis and protestations of innocence require withdrawal.	State contends substantial compliance and validity of the plea despite innocence protest.	Yes; denial reversed; plea not knowingly, voluntarily, or intelligently entered due to lack of factual basis.
Whether the plea was valid without a factual framework to measure innocence against the plea.	Jones's innocence statements necessitated factual inquiry before acceptance.	State argues plea can be valid with limited factual context.	Yes; Casale alignment shows plea invalid without basic factual framework; remand.

State v. Xie, 62 Ohio St.3d 521 (1992) (presence of pre-sentencing withdrawal standards; liberal standard)
State v. Engle, 74 Ohio St.3d 525 (1996) (plea must be knowing, intelligent, and voluntary)
State v. Nero, 56 Ohio St.3d 106 (1990) (substantial compliance standard for plea colloquy)
State v. Casale, 34 Ohio App.3d 339 (1986) (record lacked basic factual framework; plea not voluntary)
State v. Rainey, 446 N.E.2d 188 (10th Dist.1982) (sufficiency of factual basis for plea)
North Carolina v. Alford, 400 U.S. 25 (1970) (Alford plea where record shows strong factual basis despite innocence)