State v. Nettles, 2018 Ohio 4540

Travis Nettles was indicted on murder, felonious assault, weapons-under-disability, and tampering charges; firearms specifications attached. After a suppression hearing the court denied his motion to suppress statements to police.
Nettles argued statements should be suppressed because some were made before Miranda warnings and his waiver was not valid due to lack of mental-health medication and emotional state.
Toledo police later informed Nettles of his Miranda rights; he waived and gave a detailed statement. Trial court found the Maumee questioning noncustodial, the Toledo waiver valid, and denied suppression.
Nettles pled guilty to murder with a firearm specification; remaining counts were dismissed. The court sentenced him to 15 years to life plus a mandatory consecutive 3-year firearm term and a consecutive 982 days for postrelease-control violation (total 18 years to life plus 982 days).
On appeal Nettles raised three assignments: (1) suppression denial was erroneous; (2) guilty plea was involuntary; and (3) trial court imposed court/confinement/appointed-counsel costs without considering his ability to pay.
The appellate court affirmed the plea and suppression ruling (suppression claim waived by plea), but vacated the imposition of costs for confinement and appointed counsel for lack of evidence the court considered Nettles’ ability to pay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of motion to suppress should be reviewed	Nettles: statements (and waiver) involuntary; initial questioning custodial and unwarned; mental-medication status impaired waiver	State: Nettles waived by guilty plea; Maumee questioning noncustodial; Toledo waiver valid and statements voluntary	Waived by guilty plea; suppression claim not reviewed on merits
Whether guilty plea was knowing, intelligent, voluntary	Nettles: plea coerced by denial of last-minute continuance and inability to retain new counsel	State: Crim.R.11 colloquy and plea form showed Nettles understood rights/consequences; he affirmed competence and satisfaction with counsel	Plea was knowingly, intelligently, voluntarily entered; affirmed
Whether trial court properly imposed costs of prosecution	Nettles: court failed to consider present/future ability to pay when ordering costs	State: statutory provisions require assessing prosecution costs; record shows Nettles sought retained counsel (argued as evidence)	Prosecution costs validly imposed; but costs of confinement and appointed counsel vacated for lack of evidence court considered ability to pay
Remedy for unlawful imposition of costs	Nettles: requested vacatur of those costs	State: no countervailing record evidence presented	Appellate court vacated confinement and appointed-counsel costs; otherwise affirmed

State v. Beasley, 97 N.E.3d 474 (Ohio 2018) (valid guilty plea generally waives prior nonjurisdictional defects including suppression rulings)
State v. Fitzpatrick, 810 N.E.2d 927 (Ohio 2004) (guilty plea waiver of appeals of nonjurisdictional pretrial errors)
State v. Obermiller, 63 N.E.3d 93 (Ohio 2016) (same principle on plea waiver)
State v. Engle, 660 N.E.2d 450 (Ohio 1996) (guilty plea must be knowingly, intelligently, voluntarily entered; Crim.R.11 standards)
State v. Ballard, 423 N.E.2d 115 (Ohio 1981) (purpose of Crim.R.11 is to ensure defendant has necessary information to decide on plea)
State v. Clark, 893 N.E.2d 462 (Ohio 2008) (strict compliance required for advising constitutional rights under Crim.R.11)
State v. Nero, 564 N.E.2d 474 (Ohio 1990) (substantial compliance standard for nonconstitutional aspects of Crim.R.11)