State v. Price
2015 Ohio 315
Ohio Ct. App.2015Background
- Anthony M. Price pleaded guilty in three indictments to a total of two burglary-related felonies and nine aggravated-robbery felonies (eight carrying firearm specifications).
- Pleas were entered in two stages: a multi-count plea (including eight aggravated robberies and an attempted burglary with firearm specs) and, five months later, a guilty plea to an additional aggravated robbery.
- The trial court sentenced Price to an aggregate of 22 years, ordering multiple terms to run consecutively and imposing several three-year firearm specification terms.
- Price challenged (1) the voluntariness/knowledgeability of his pleas, arguing the court misstated minimum/maximum exposure for firearm specs, and (2) the court’s failure to make the statutory findings required by R.C. 2929.14(C)(4) before imposing consecutive sentences.
- The appellate court reviewed the plea colloquy under Crim.R. 11(C)(2) and the sentencing judge’s statements and findings under R.C. 2929.14(C)(4).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pleas were knowing, intelligent, voluntary under Crim.R. 11(C)(2) given alleged misstatements about firearm-spec exposure | State: Plea colloquy properly warned of maximum exposure and judge correctly described possible firearm terms | Price: Court misstated minimum/maximum for firearm specifications, so plea was not knowing/voluntary | Court: Plea colloquy complied with Crim.R. 11(C)(2); pleas were knowing, intelligent, voluntary; second assignment overruled |
| Whether trial court made required findings under R.C. 2929.14(C)(4) before imposing consecutive sentences | State: Court complied with prior appellate guidance and engaged in meaningful dialog warranting consecutive terms | Price: Consecutive sentence findings were insufficient/absent | Court: Court’s sentencing complied with this court’s prior rulings; R.C. 2929.14(C)(4) requirement satisfied; first assignment overruled |
Key Cases Cited
(No cases with official reporter citations appear in the opinion; the court relied on its own recent unreported/slip opinions.)