State v. Rogenski, 2020 Ohio 1360

Alicia Rogenski was indicted on multiple counts arising from the killing, dismemberment, and attempted concealment of Scottie Johnson, including aggravated murder, murder, aggravated robbery, abuse of a corpse, tampering with evidence, and complicity-related counts.
Rogenski pleaded guilty pursuant to a plea agreement to murder (R.C. 2903.02(A)) and first-degree aggravated robbery (R.C. 2911.01(A)(1)); the state dismissed remaining counts and recommended concurrent sentences: 15 years to life for murder and 3 years for aggravated robbery.
At plea colloquy Rogenski admitted shooting the victim in the head with her co-defendant to steal money/drugs; she confirmed satisfaction with counsel and the guilty plea was accepted; sentencing was set later after a PSI.
At sentencing the court imposed the agreed concurrent terms; the sentencing entry included a five-year postrelease-control (PRC) advisement for the aggravated-robbery conviction but the oral PRC advisement at sentencing was incomplete.
Rogenski appealed, claiming ineffective assistance of counsel during plea, that her plea was not knowing/voluntary under Crim.R. 11, and that the trial court failed to properly advise on PRC at sentencing.
The appellate court affirmed the plea and rejected the ineffective- assistance and Crim.R. 11 claims, but found the sentencing PRC advisement deficient and vacated/remanded only the PRC portion of the sentence for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective in advising/ investigating before the plea	State: record shows counsel actively pursued discovery, motions, and negotiated a favorable plea; no deficient performance shown	Rogenski: counsel failed to investigate/explain exculpatory evidence and her understanding; learning-disability concerns	Held: No ineffective assistance; counsel was active in discovery and plea was beneficial; Rogenski failed to show prejudice
Whether plea was knowing, intelligent, voluntary under Crim.R. 11 (nonconstitutional advisements)	State: court properly advised of nature of charges, maximum penalties, and postrelease control at plea; written advisals accurate	Rogenski: some nonconstitutional advisements (e.g., court could immediately sentence) were omitted or written forms confusing	Held: Substantial compliance with Crim.R. 11; omitted warning about immediate sentencing caused no prejudice because court did not sentence immediately
Whether sentencing advisement on postrelease control was adequate	State: sentencing entry and plea advisement referenced PRC; concurrent sentence with murder (unclassified felony) affects applicability	Rogenski: oral advisement at sentencing failed to state PRC term, whether mandatory/discretionary, and violation consequences	Held: Oral advisement at sentencing was incomplete; PRC imposition vacated and case remanded for a resentencing hearing limited to PRC issues

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
State v. Bradley, 42 Ohio St.3d 136 (Ohio 1989) (Ohio articulation of Strickland standard)
State v. Madrigal, 87 Ohio St.3d 378 (Ohio 2000) (both Strickland prongs required)
State v. Veney, 120 Ohio St.3d 176 (Ohio 2008) (strict compliance required for constitutional advisements; substantial compliance for nonconstitutional advisements)
State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (substantial compliance standard for Crim.R. 11 nonconstitutional advisements)
State v. Sarkozy, 117 Ohio St.3d 86 (Ohio 2008) (postrelease-control is a nonconstitutional advisement)
State v. Jordan, 104 Ohio St.3d 21 (Ohio 2004) (statutory requirements for PRC notice at sentencing)
State v. Grimes, 151 Ohio St.3d 19 (Ohio 2017) (trial court must notify about PRC details and include them in the entry)
State v. Qualls, 131 Ohio St.3d 499 (Ohio 2012) (PRC details and consequences must be explained)
State v. Billiter, 134 Ohio St.3d 103 (Ohio 2012) (PRC notification requirements clarified)
State v. Fischer, 128 Ohio St.3d 92 (Ohio 2010) (remedy: vacate PRC and remand for resentencing limited to PRC)