State v. Jones, 2011 Ohio 1918

Jones was indicted in June 2009 on drug possession (CR-524898) and in July 2009 on theft (CR-525895).
A court psychiatric clinic diagnosed depression, psychosis, and PCP use but found Jones competent and sane for trial.
In September 2009 Jones pled guilty to one drug-possession count and one theft count; other counts were nolled; sentences were two consecutive one-year terms.
Jones filed a delayed appeal with two assignments of error challenging the voluntariness of the plea and effectiveness of counsel.
During the plea hearing, the court explained possible penalties and postrelease control; a comment about limited good-time credit was made.
The court ruled that the plea substantially complied with Crim.R. 11 and RC 2943.032, rejected both assignments, and affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Crim.R.11 compliance regarding postrelease control	Jones argues plea was invalid due to misstatement on postrelease control and good-time credit.	Jones contends the court’s statements rendered the plea involuntary.	Substantial compliance; no prejudice; plea valid.
Ineffective assistance for not transferring to mental health docket	Jones claims counsel should have moved to transfer to mental health docket.	Jones was not diagnosed with severe mental illness; transfer not required.	No error; second assignment overruled.

State v. Nero, 56 Ohio St.3d 106 (1990) (nonconstitutional rights require substantial compliance)
State v. Griffin, 2004-Ohio-4344 (Ohio App. Dist.) (postrelease-control explanation necessary for understanding penalties)
State v. Conrad, 2007-Ohio-5717 (Ohio App. Dist.) (substantial compliance when postrelease control explained)
State v. Jones, 2001-Ohio-1295 (Ohio App. Dist.) (precedes: discretionary appeal not allowed; relevance to misstatements)
State v. Spates, 64 Ohio St.3d 269 (1992) (plea challenge limitations after guilty plea)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance standard)