State v. Mayle, 101 N.E.3d 490

Mayle was indicted for felonious assault; he entered an Alford guilty plea to amended charge of attempted felonious assault (third-degree felony) and was placed on two years of intensive community control.
At sentencing the court warned that violating community control could subject Mayle to a 30-month prison term.
After about 15 months the court issued a capias alleging Mayle repeatedly failed to comply (chiefly failure to report); he was arrested and jailed.
At a probable-cause hearing Mayle, claiming inadequate jail medical care, waived contesting the violation and admitted the community-control violation after consulting counsel.
The trial court accepted the admission, found Mayle not amenable to community control, and imposed the previously-noted 30-month prison term.
Mayle appealed, arguing (1) the admission was a de facto Alford plea that required Piacella protections, and (2) the court erred by not advising him at the violation hearing of the 30-month exposure and by not expressly citing R.C. 2929.11/2929.12 at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by accepting Mayle's admission as a de facto Alford plea without Piacella protections	State: Alford does not apply to revocation hearings; Crim.R. 32.3 governs and was followed	Mayle: Admission functioned like an Alford plea and should not be accepted where motive was to obtain medical care rather than admit culpability	Court: Alford and Crim.R.11 plea protections do not extend to community-control revocation hearings; Crim.R.32.3 requirements were satisfied — no error
Whether the court erred by not informing Mayle at the violation hearing of the 30-month exposure and by not expressly citing R.C. 2929.11/2929.12	State: Fraley only requires notice of potential future sentence at original sentencing (or prior revocation), not repetition at the violation hearing; courts need not recite R.C. 2929.11/2929.12 verbatim	Mayle: He should have been told at the violation proceeding that admission could trigger 30 months; court should have expressly considered R.C. 2929.11/2929.12	Court: No duty to repeat the potential term at the revocation hearing under Fraley; silence on R.C. 2929.11/2929.12 does not rebut presumption they were considered; sentence affirmed

North Carolina v. Alford, 400 U.S. 25 (1970) (guilty pleas accepted despite protestations of innocence under limited circumstances)
State v. Piacella, 27 Ohio St.2d 92 (1971) (procedural safeguards for accepting guilty pleas in Ohio)
State v. Fraley, 105 Ohio St.3d 13 (2004) (requirement to inform defendant at original sentencing or prior revocation of potential prison term for future violations)
State v. Jackson, 150 Ohio St.3d 362 (2016) (defendant entitled to allocution after violation finding before imposition of prison term)