State v. Reed, 2015 Ohio 3534

Phillip G. Reed pleaded guilty pursuant to a plea agreement to multiple counts: one second-degree felony burglary, two third-degree felony burglaries, one fifth-degree felony theft from an elderly person, and two counts of petty theft.
Trial court imposed an aggregate prison term of nine years and fines totaling $5,500, with some sentences ordered concurrent and others consecutive.
Appellant's counsel filed an Anders brief and a motion to withdraw, asserting the appeal was frivolous and identifying two potential assignments of error.
No pro se brief or additional assignments were filed by Reed.
The appellate court conducted an independent review of the record under Anders and addressed two issues: Crim.R. 11 plea process compliance and whether the sentence was contrary to law or an abuse of discretion.
The court affirmed the judgment, granted counsel leave to withdraw, and found no arguable merit to the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with Crim.R. 11 when accepting Reed's guilty plea	State: Trial court substantially complied with Crim.R. 11; Reed was informed of rights, penalties, and post-release control and plea was voluntary	Reed: Trial court failed to comply with Crim.R. 11 requirements before accepting plea	The court held the trial court complied with Crim.R. 11 (substantial compliance) and overruled the claim
Whether the sentence was clearly and convincingly contrary to law or an abuse of discretion	State: Sentences were within statutory ranges; required findings for consecutive sentences were made; sentence was supported by factors and criminal history	Reed: Sentence was unlawful or an abuse of discretion (challenging length/consecutive structure)	The court held the sentence was not contrary to law, statutory findings for consecutive terms were made, and the court did not abuse its discretion

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedure when counsel seeks to withdraw on grounds appeal is frivolous)
State v. Ballard, 66 Ohio St.2d 473 (Ohio 1981) (substantial compliance test for Crim.R. 11 nonconstitutional matters)
State v. Griggs, 103 Ohio St.3d 85 (Ohio 2004) (analysis for determining substantial compliance with Crim.R. 11)
State v. Kalish, 120 Ohio St.3d 23 (Ohio 2008) (two-step standard for appellate review of felony sentences)
State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (requirement for trial court to make statutory findings when imposing consecutive sentences)
State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (prejudice test for nonconstitutional Crim.R. 11 errors)
State v. Sarkozy, 117 Ohio St.3d 86 (Ohio 2008) (consideration of whether defendant subjectively understood plea under substantial-compliance standard)