State v. Morgan, 104 N.E.3d 941

Issac Morgan was indicted on multiple counts including rape; he pleaded guilty to one count of rape with an accompanying three-year firearm specification in exchange for dismissal of other counts.
At the plea hearing the court advised Morgan of the maximum penalty for rape and that the firearm specification carried a mandatory consecutive three-year term; the court did not tell Morgan that rape itself required a mandatory prison term or that he was ineligible for community control.
Morgan signed a plea form that erroneously indicated "PRISON TERM IS MANDATORY n/a," suggesting (incorrectly) that a mandatory term did not apply.
The trial court accepted the plea and later sentenced Morgan to 10 years on rape plus a consecutive mandatory three years on the firearm spec (aggregate 13 years) and designated him a Tier III sex offender.
Morgan appealed, arguing his guilty plea was not knowing, intelligent, and voluntary because the court failed to comply with Crim.R. 11(C)(2) regarding mandatory prison and community-control ineligibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the plea was knowing/voluntary under Crim.R. 11(C)(2)(a) because the court failed to advise that rape carries a mandatory prison term making defendant ineligible for community control	State: Court substantially complied by advising of the maximum penalty and the mandatory three-year firearm term; that was sufficient	Morgan: Court never advised rape itself carried a mandatory prison term or that he was ineligible for community control; plea form was incorrect, so plea was unknowing and involuntary	Court: Reversed — trial court failed to substantially comply with Crim.R. 11(C)(2)(a); no prejudice analysis required; plea invalid

Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (plea must be knowing and voluntary to satisfy due process)
State v. Johnson, 40 Ohio St.3d 130 (Ohio 1988) (trial court must ensure plea is knowing, intelligent, and voluntary)
State v. Clark, 119 Ohio St.3d 239 (Ohio 2008) (trial courts urged to literal compliance with Crim.R. 11 and strict compliance for constitutional rights)
State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (nonconstitutional Crim.R. 11 requirements require substantial compliance)
State v. Veney, 120 Ohio St.3d 176 (Ohio 2008) (defendant must show prejudice when only nonconstitutional Crim.R. 11 obligations are at issue)
State v. Sarkozy, 117 Ohio St.3d 86 (Ohio 2008) (complete failure to comply with Crim.R. 11(C)(2)(a) or (b) avoids prejudice analysis)