State v. Maggard, 2011 Ohio 4233

State indicted Maggard on six counts of rape, four counts of kidnapping, and four counts of abduction; no plea agreement was reached.
Maggard pleaded no contest to all charges after the trial court denied his suppression motion.
The trial court merged abduction and kidnapping counts for sentencing, imposing a 20-year term.
The court later held that Crim.R. 11 was not substantially complied with for the rape pleas, leading to vacatur of those six rape convictions.
The kidnapping and abduction convictions remained intact; the case was remanded for reclassification of sex offender status and to correct clerical sentencing entries.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court substantially comply with Crim.R.11(C)(2)(a) for rape pleas?	Maggard	Maggard	No; rape pleas vacated
Were the rape plea defects prejudicial, given independent counts without a plea agreement?	Maggard	Maggard	Counts independent; only rape pleas reversed
Did the trial court abuse its discretion in denying Maggard’s motion to dismiss counsel?	State	Maggard	No abuse of discretion
Was there ineffective assistance of counsel related to the plea voluntariness issue?	State	Maggard	No need to address because rape convictions vacated; ostatial issues preserved

State v. Nero, 56 Ohio St.3d 106 (Ohio Supreme Court 1990) (nonconstitutional Crim.R.11 compliance can be substantial if defendant understands rights)
State v. Farley, 2002-Ohio-1142 (Ohio 1st Dist. 2002) (probation ineligibility can affect voluntariness of plea; may require reversal when no agreement)
State v. Stewart, 51 Ohio St.2d 86 (Ohio Supreme Court 1977) (Crim.R.11 constitutional aspects require strict compliance; nonconstitutional aspects strongly preferred)
State v. Saxon, 109 Ohio St.3d 176 (Ohio Supreme Court 2006) (sentence package doctrine and independent counts; reversal not automatic across counts)
State v. Keenan, 81 Ohio St.3d 133 (Ohio Supreme Court 1998) (procedural compliance and prejudice considerations in Crim.R.11)