State v. Rogers, 157 N.E.3d 142

Rogers was indicted on multiple drug and weapon offenses; plea deal (Oct 31, 2019): guilty to aggravated drug trafficking (Count 2, 2nd-degree felony with forfeiture spec), having weapons while under disability (Count 4), and amended cocaine possession (Count 6); state dismissed other counts and firearm specs.
Guilty-plea form signed by Rogers listed penalties including a mandatory $7,500 fine on Count 2 and possible license suspensions; during the oral Crim.R. 11 colloquy the trial court explained prison terms but did not orally advise Rogers of the mandatory $7,500 fine or other fines/license suspensions.
Sentencing occurred immediately; defense counsel had filed a motion the same day to waive the $7,500 fine based on indigency and notified the court at sentencing; the court imposed the $7,500 mandatory fine and prison terms as indicated.
Rogers appealed, arguing his plea was not knowingly, intelligently, and voluntarily made because the trial court failed to advise him orally of the mandatory fine in violation of Crim.R. 11(C)(2)(a).
The appellate court applied the Ohio Supreme Court’s Crim.R. 11 framework (as set out in Dangler and Sarkozy), concluded the trial court completely failed to comply with Crim.R. 11(C)(2)(a) by wholly omitting a distinct component of the maximum penalty (the mandatory fine), vacated Rogers’ plea and sentence, and remanded for further proceedings; the challenge to R.C. 2967.271 was rendered moot by that disposition.

Issue	Plaintiff's Argument (Rogers)	Defendant's Argument (State/Trial Court)	Held
Whether Rogers’ guilty plea was knowing, intelligent, and voluntary under Crim.R. 11 when the court failed to orally advise of the mandatory $7,500 fine	Rogers: plea involuntary because the trial court did not personally advise him of the mandatory $7,500 fine before accepting the plea, violating Crim.R. 11(C)(2)(a)	State: substantial compliance — Rogers signed a plea form that listed the fine; trial court explained prison exposure; omission was not a complete failure and defendant suffered no prejudice	Held: Reversed. The court found the trial court did not comply with Crim.R. 11(C)(2)(a); omission of the mandatory fine was a complete failure to advise on a distinct component of the maximum penalty under Sarkozy/Dangler, so prejudice need not be shown and the plea was vacated
Whether R.C. 2967.271 (Reagan Tokes indeterminate sentencing) is unconstitutional	Rogers: statute violates separation of powers and due process	State: statute is constitutional; prior appellate decisions so hold	Held: Moot. Because the plea/vacatur resolved the case, the court declined to decide the constitutional challenge (noting prior appellate rulings upholding the statute)

State v. Sarkozy, 117 Ohio St.3d 86 (Ohio 2008) (trial court's complete omission of advising a distinct component of the maximum penalty requires vacating plea)
State v. Bishop, 156 Ohio St.3d 156 (Ohio 2018) (Crim.R. 11(C) plea-colloquy requirements)
State v. Clark, 119 Ohio St.3d 239 (Ohio 2008) (limited exceptions to prejudice requirement in Crim.R. 11 review)
State v. Veney, 120 Ohio St.3d 176 (Ohio 2008) (same—context on Crim.R. 11 prejudice exceptions)
Wilson v. Kasich, 134 Ohio St.3d 221 (Ohio 2012) (courts properly presume statute constitutionality unless challenger proves otherwise)