State v. Mills, 2021 Ohio 1180

Cody Mills was indicted on multiple drug- and weapon-related felonies and, after plea negotiations, pled guilty to aggravated trafficking and trafficking in heroin; other counts were dismissed.
The trial court imposed an indefinite prison term of 10 to 15 years under the Reagan Tokes Act (R.C. 2967.271).
Mills appealed, raising three assignments of error: (1) R.C. 2967.271 is unconstitutional under federal and state constitutions; (2) trial counsel was ineffective for failing to object to the indefinite sentence; and (3) his guilty pleas were not knowingly, intelligently, and voluntarily made because the court failed to advise him he had the right to have the state prove guilt "beyond a reasonable doubt."
The court held the constitutional challenges to R.C. 2967.271 and the ineffective-assistance claim were not ripe because Mills had not yet served his minimum term or been subject to a DRC extension under the statute.
The court rejected Mills’ plea-voluntariness claim after the court reporter filed an affidavit correcting the plea transcript to show the trial court had advised Mills of the right to have the state prove guilt beyond a reasonable doubt.
The judgment of the Coshocton County Court of Common Pleas was affirmed; one judge concurred in part and dissented in part as to ripeness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of R.C. 2967.271 (Reagan Tokes Act)	State: statute is valid and applies to indefinite sentences	Mills: statute violates separation of powers and due process by letting DRC extend incarceration administratively	Not ripe for review because Mills has not yet been subject to an extension under the statute
Ineffective assistance for failing to object to indefinite sentence	State: counsel’s conduct not yet reviewable on this ground since the statute’s application is not yet realized	Mills: counsel should have objected to the constitutionality of R.C. 2967.271	Not ripe for review for the same reason as the constitutional challenge
Voluntariness of guilty plea (failure to advise of proof-beyond-a-reasonable-doubt)	State: plea was properly advised and valid	Mills: plea was involuntary because transcript omitted the phrase "beyond a reasonable doubt"	Held voluntary; court reporter filed an affidavit correcting the transcript to include the advisement, so the plea was knowing and voluntary

State ex rel. Elyria Foundry Co. v. Indus. Comm., 82 Ohio St.3d 88 (1998) (discusses ripeness doctrine and timing for judicial review)
Regional Rail Reorganization Act Cases, 419 U.S. 102 (1974) (ripeness as a timing and prudential limitation on judicial review)
Abbott Laboratories v. Gardner, 387 U.S. 136 (1967) (ripeness principles and avoidance of premature adjudication)