State v. Perdue, 2022 Ohio 722

On Jan. 11, 2020, Christopher Perdue set fire to an unoccupied residence; the fire destroyed that structure and spread damage to an adjacent occupied home. He later committed related burglaries and cut a power line.
Perdue was indicted on multiple counts including aggravated arson, burglary, disrupting public services, and possessing criminal tools; he pleaded guilty to one count each of aggravated arson, burglary, and disrupting public services in exchange for dismissal of remaining counts and concurrent sentences.
At the Sept. 22, 2020 plea hearing Perdue signed a plea form and an arson-registration notification form, but the trial court did not verbally advise him of arson-registration requirements during the plea colloquy.
At sentencing the court placed the arson-registration obligations on the record, confirmed Perdue had signed and understood the form, and imposed concurrent prison terms (including 8–12 years for aggravated arson).
Perdue appealed, arguing his guilty plea was not knowing, intelligent, and voluntary because the court failed at the plea hearing to advise him of mandatory arson-offender registration requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s failure at the plea hearing to advise Perdue of arson-offender registration requirements rendered his plea involuntary under Crim.R. 11 and due process	Registration requirements are remedial collateral consequences, not part of the maximum penalty; court not required to advise at plea (and Perdue signed/acknowledged the form).	Registration is punitive and part of the maximum penalty; complete failure to advise requires strict compliance and vacatur of the plea.	The court held arson-registration requirements are remedial collateral consequences, not part of the maximum penalty; the trial court was not required to inform Perdue at the plea hearing, and the plea was affirmed.

Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (pleas must be knowing, intelligent, and voluntary)
State v. Williams, 129 Ohio St.3d 344, 952 N.E.2d 1108 (Ohio 2011) (Adam Walsh sex-offender scheme found punitive in aggregate)
State v. Dangler, 162 Ohio St.3d 1, 164 N.E.3d 286 (Ohio 2020) (nonconstitutional Crim.R. 11 errors require a showing of prejudice)
State v. Miller, 159 Ohio St.3d 447, 151 N.E.3d 617 (Ohio 2020) (strict compliance required for Crim.R. 11 provisions implicating constitutional rights)
State v. Caldwell, 18 N.E.3d 467 (1st Dist. 2014) (arson-registration scheme is remedial and may be applied retroactively)