State v. Little, 2019 Ohio 745

Jordan A. Little was indicted on multiple counts of pandering sexually oriented matter involving a minor and one count of illegal use of a minor in nudity-oriented material; he agreed to plead guilty to two second-degree counts in exchange for dismissal of the remaining counts.
Written plea informed Little each count carried a possible 2–8 year prison term and contained no sentence recommendation; it also said he was forfeiting the right to "call witnesses."
At the change-of-plea hearing the court personally addressed Little, explained constitutional rights (including that he could "summon" witnesses), and found the pleas knowing, voluntary, and intelligent.
A presentence investigation showed no adult criminal record but prior juvenile delinquency adjudications.
At sentencing the court imposed consecutive four-year prison terms on each count (aggregate eight years), finding consecutive terms necessary and making the statutorily required findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea colloquy complied with Crim.R. 11(C)(2) regarding compulsory process	The State argued the court’s colloquy satisfied Rule 11 and conveyed the rights waived by pleading guilty	Little argued the court failed to properly inform him of his right to compulsory process because the plea paperwork said he forfeited the right to call witnesses and the oral magistrate language was insufficient	Court held Rule 11 satisfied: telling defendant he was "entitled to summon witnesses" adequately conveyed the right to compulsory process, so plea was valid
Whether juvenile delinquency adjudications may be considered when imposing consecutive sentences under R.C. 2929.14(C)(4)	The State argued the court may consider juvenile adjudications as part of defendant’s history of criminal conduct for sentencing purposes	Little argued juvenile adjudications are not criminal convictions and thus cannot be used to justify consecutive sentences	Court held juvenile adjudications may be considered in sentencing (per R.C. 2929.12) and the trial court made the required consecutive-sentence findings; no abuse of discretion

State v. Barker, 953 N.E.2d 826 (Ohio 2011) (interpreting language conveying right to compulsory process)
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must state consecutive-sentence findings on the record)
State v. Hand, 73 N.E.3d 448 (Ohio 2016) (juvenile adjudications are not criminal convictions for purposes of sentence enhancement)