State v. Richie, 2014 Ohio 1114

Stephen Richie was charged with one count of second-degree felony burglary and pled guilty on February 8, 2013.
On February 20, 2013 the trial court sentenced Richie to two years imprisonment, 60 days jail-time credit, three years post-release control, and court costs.
Richie filed a timely appeal on March 14, 2013. Appointed counsel filed an Anders brief asserting no meritorious issues.
The appellate court notified Richie of the Anders filing and invited a pro se brief; Richie did not file a timely response despite extensions.
Counsel identified one potential issue: whether Richie’s guilty plea was knowingly, intelligently, and voluntarily entered under Crim. R. 11(C)(2).
The appellate court reviewed the plea colloquy, PSI, and sentencing transcript and found the trial court complied scrupulously with Crim. R. 11(C)(2). The court affirmed the conviction and sentence as frivolous on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the guilty plea was entered knowingly, intelligently, and voluntarily under Crim. R. 11(C)(2)	Trial court complied with Crim. R. 11(C)(2); plea was valid	Richie (via Anders brief) suggested no arguable merit but raised claim that plea was not knowing/voluntary	Court found the trial court scrupulously complied with Crim. R. 11(C)(2) and plea was knowing, intelligent, and voluntary; appeal frivolous

Anders v. California, 386 U.S. 738 (1967) (framework for counsel withdrawing when no meritorious appellate issues exist)
State v. Engle, 74 Ohio St.3d 525 (1996) (guilty pleas must be knowingly, intelligently, and voluntarily made)
State v. Jabbaar, 991 N.E.2d 290 (Ohio 2013) (same constitutional standard for guilty pleas)