State v. Rohra, 545 S.W.3d 344

Rohra was charged with unlawful possession of a firearm (§ 571.070) based on prior Oklahoma convictions; he also pled guilty to possession of marijuana and paraphernalia.
Rohra moved to dismiss, arguing the Oklahoma court entered a deferred judgment and thus did not have a qualifying prior "conviction" for § 571.070; the circuit court overruled the motion.
Rohra then entered an unconditional guilty plea after the court and prosecutor explained rights and the factual basis; the court found the plea voluntary and accepted it.
The circuit court sentenced Rohra to four years (execution suspended) and two years probation for the firearm offense.
Rohra appealed, arguing the charging document was insufficient because the deferred Oklahoma judgment was not a "conviction."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the charge sufficiently alleged a prior "conviction" when the Oklahoma disposition was a deferred judgment	Rohra: Deferred judgment is not a conviction, so charging document is insufficient	State: Charging document tracked statutory language alleging a prior conviction; factual sufficiency was adequate	Court: Claim waived by unconditional guilty plea; charging document alleged the element in statutory language, so not reviewable on direct appeal

United States v. Broce, 488 U.S. 563 (a guilty plea admits the substantive elements of the offense and waives many defenses)
Garris v. State, 389 S.W.3d 648 (Mo. banc 2012) (guilty plea waives nonjurisdictional defects)
State v. Craig, 287 S.W.3d 676 (Mo. banc 2009) (limits on direct appeal after unconditional guilty plea; exceptions for subject-matter jurisdiction and charging-document sufficiency)
State v. O'Connell, 726 S.W.2d 742 (Mo. banc 1987) (indictment must allege essential elements to inform the defendant)