State v. Patton, 2017 Ohio 1197

Paul W. Patton was indicted for one count of breaking and entering (R.C. 2911.13(A)), a fifth-degree felony; he pled guilty on April 15, 2016.
The trial court accepted the plea after a plea colloquy and Patton signed a written plea form.
On May 10, 2016 the court sentenced Patton to 12 months’ imprisonment, to be served consecutively to another Clark County sentence.
On appeal Patton argued (1) his guilty plea was not knowing, intelligent, and voluntary because the court’s advisements were lengthy, barely comprehensible given his tenth‑grade education, and omitted certain explanations; and (2) his conviction was against the manifest weight of the evidence.
The appellate court reviewed the plea colloquy and plea form, finding the court properly advised Patton of constitutional rights, the effect of the plea, and that the State must prove guilt beyond a reasonable doubt; the only minor omission (that the court could proceed to judgment and sentence upon acceptance) appeared in the written plea form.
The court affirmed the conviction, overruling both assignments of error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the guilty plea was knowingly, intelligently, and voluntarily entered	State: trial court complied with Crim.R. 11 and adequately advised Patton; plea form supplemented any omissions	Patton: court’s oral advisement was “lengthy” and barely comprehensible given his education; court failed to advise that State must prove each element beyond a reasonable doubt and failed to explain effect of plea	Court held plea was knowing, intelligent, and voluntary; strict compliance with constitutional advisements and substantial compliance with non-constitutional advisements
Whether the conviction is against the manifest weight of the evidence	State: guilty plea is an admission of guilt and waives right to challenge weight/sufficiency	Patton: conviction against manifest weight	Court held manifest-weight claim barred by guilty plea; overruled assignment

Boykin v. Alabama, 395 U.S. 238 (1969) (guilty plea must be voluntary, knowing, and intelligent to comport with due process)
State v. Nero, 56 Ohio St.3d 106 (1990) (trial court must substantially comply with Crim.R. 11(C)(2)(a) and (b); substantial compliance measured by defendant’s subjective understanding)
State v. Clark, 119 Ohio St.3d 239 (2008) (trial court must strictly comply with Crim.R. 11(C)(2)(c) regarding waiver of constitutional rights)
State v. Veney, 120 Ohio St.3d 176 (2008) (Crim.R. 11(C) governs felony pleas and the required advisements)
State v. Griggs, 103 Ohio St.3d 85 (2004) (guilty plea waives right to challenge sufficiency or manifest weight of the evidence)