State v. Rodriguez, 101 N.E.3d 1154

Victor R. Rodriguez was indicted for rape and sexual battery (charges arising from an incident where the victim had memory loss and DNA evidence matched the defendant).
After voir dire revealed multiple jurors with prior sexual-abuse experience, Rodriguez entered an Alford plea to the lesser-included offense of attempted gross sexual imposition (fifth-degree felony).
At the plea colloquy the trial court misstated the length of post-release control as a "maximum of three years," but the plea form and the later sentencing entry correctly reflected a mandatory five-year post-release-control term.
The trial court accepted the plea, ordered a PSI, and later sentenced Rodriguez to 11 months incarceration, five years mandatory post-release control, 15-year Tier I registration, and jail-time credit.
Rodriguez appealed, arguing (1) his plea was not knowing and voluntary because of the court's misstatement about post-release control, and (2) the court erred in claiming no presumption of community control and in imposing an 11‑month prison term.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Rodriguez)	Held
Whether plea was knowing and voluntary given trial court's misstating post-release control term	Trial court partially complied with Crim.R.11; no prejudice shown because plea motivated by juror composition and plea form contained correct five-year term	Misstatement that post-release control was up to three years rendered plea unknowing and involuntary	Court: Partial compliance; no prejudicial effect shown. Plea upheld.
Whether presumption of community control applied and sentence lawful	Presumption inapplicable because conviction is a sex offense under R.C. Chapter 2907; court had discretion to impose prison	Argues there is a presumption for 4th/5th-degree felonies and court failed to properly consider sentencing principles	Court: Presumption excluded for Chapter 2907 sex offenses; sentence within statutory range and supported by findings; affirmed.

North Carolina v. Alford, 400 U.S. 25 (1970) (permits a defendant to enter a guilty plea while maintaining innocence under pressure of likely conviction)
State v. Clark, 119 Ohio St.3d 239 (2008) (Crim.R. 11 nonconstitutional-rights substantial-compliance standard and prejudicial-effect test)
State v. Nero, 56 Ohio St.3d 106 (1990) (defendant must subjectively understand implications of plea; discussed in Clark)
State v. Marcum, 146 Ohio St.3d 516 (2016) (appellate review of felony sentences limited to clear-and-convincing standard under R.C. 2953.08(G)(2))