State v. Sledge, 2016 Ohio 4904

Appellant Bryan Sledge was indicted on multiple counts of gross sexual imposition and rape based on allegations he sexually abused two young girls (ages 7 and 4 in 2012).
The state moved in limine under Ohio’s rape-shield statute, R.C. 2907.02(D), to exclude evidence that the child complainants had previously accused their biological father of sexual abuse.
After the court granted the motion in limine, the state offered a plea alternative tied to a stipulated polygraph; Sledge took the polygraph (results: deceptive) and entered a no-contest plea to amended charges (two counts GSI and one count rape without age specification).
Sledge later filed a pre-sentence motion to withdraw his plea, asserting coercion/pressure from counsel and his mother, persistent claims of innocence, and that the plea was induced by erroneous advice about preserving appellate issues relating to the in limine ruling.
The trial court denied the motion to withdraw, sentenced Sledge to 17 years, and Sledge appealed contesting (1) denial of plea withdrawal and (2) exclusion of evidence about prior accusations against the biological father (confrontation/cross-examination rights).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Sledge)	Held
Whether exclusion under R.C. 2907.02(D) of evidence that complainants previously accused another person of abuse was proper	The rape-shield ruling barred such evidence; the in limine ruling was appropriate to prevent irrelevant/prejudicial testimony	Evidence of prior involuntary abuse accusations is not volitional sexual activity and is material to credibility and origin of children’s sexual knowledge; exclusion violated confrontation and cross-examination rights	Court held that prior-child-abuse accusations may fall outside R.C. 2907.02(D)’s bar, but Sledge waived appellate review by entering a no-contest plea without preserving the objection; thus second assignment not well-taken
Whether the trial court abused discretion by denying Sledge’s pre-sentence motion to withdraw his no-contest plea	The plea was knowingly, intelligently, and voluntarily entered after extensive negotiations and colloquy; withdrawal was a change of heart	Plea was induced by counsel’s and mother’s pressure and by reliance on preserving appellate issues after the in limine ruling; asserted innocence	Court found the record showed the plea was not knowingly, intelligently, and voluntarily entered given counsel’s advice about appellate preservation and related inducement; plea vacated and case remanded

Grubb v. State, 28 Ohio St.3d 199 (motion in limine described; used to explain purpose of limiting pretrial rulings)
Defiance v. Kretz, 60 Ohio St.3d 1 (preliminary in limine rulings are not final; court may revise at trial)
State v. French, 72 Ohio St.3d 446 (distinguishing motion in limine from motion to suppress)
State v. Engle, 74 Ohio St.3d 525 (guilty/no-contest pleas must be knowing, voluntary, and intelligent)
In re Michael, 119 Ohio App.3d 112 (holding exclusion of prior allegations against third party could be unreasonable in some contexts)
State v. Nero, 56 Ohio St.3d 106 (standards for whether plea was knowing and intelligent)