State v. Knox, 2015 Ohio 4198

Christopher Knox pleaded guilty to 21 counts of third-degree burglary, one count of possession of criminal tools, and one count of receiving stolen property; sentences were imposed with no plea-sentencing agreement.
Knox admitted to burglarizing multiple homes to steal copper to fund a heroin addiction and has prior burglary/theft convictions.
Plea forms and the court discussed post-release control; the court told Knox post-release control was discretionary, but the written termination entry treated post-release control for the burglaries as mandatory.
The termination entry ordered 3 years of post-release control for the 21 burglary convictions and imposed $6,760 total restitution, including $1,000 to the victim(s) listed in Counts 3 and 5.
The presentence investigation (PSI) identified victims for each count but supplied loss amounts for only five victims, with no supporting documentation; the PSI contained no documented loss or verification for the victim(s) in Counts 3 and 5.
Knox appealed, arguing his plea was not knowing/voluntary because the court misadvised him about mandatory post-release control and that the restitution award for one victim lacked record support.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Knox's guilty plea was not knowing/voluntary because the court misadvised him that post-release control was discretionary when it was mandatory for his burglary convictions	State: Court substantially complied with Crim. R. 11 by advising about post-release control; any misstatement was partial and Knox must show prejudice	Knox: Misstatement rendered plea unintelligent because he was not informed post-release control was mandatory	Court: Overruled. Partial compliance sufficed; Knox failed to show prejudice or that he would have pled differently if correctly advised
Whether restitution of $1,000 to the victim(s) in Counts 3 and 5 is supported by competent, credible evidence	State: Conceded the restitution was unsupported and must be corrected	Knox: Restitution lacked evidentiary support in PSI/documents and was therefore improper	Court: Sustained. Restitution order for that victim reversed; remanded to correct termination entry

Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (a guilty plea must be voluntary, knowing, and intelligent)
State v. Griggs, 103 Ohio St.3d 85 (Ohio 2004) (failure to inform defendant of constitutional rights invalidates a plea)
State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (substantial compliance with Crim. R. 11 is sufficient for nonconstitutional advisements; prejudice must be shown)
State v. Johnson, 40 Ohio St.3d 130 (Ohio 1988) (knowledge of maximum penalty not constitutionally required for a valid plea)
State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (plain-error standard and requirement that error affect substantial rights)