State v. Smith, 2011 Ohio 3288

Smith was convicted after no-contest pleas in two Montgomery County cases, with life sentence in one case to run concurrently with a nine-year sentence in the other.
Smith challenged suppression of statements made during custodial interrogation after Miranda warnings, arguing coercion and violation of rights.
Detective Gaier and another officer interviewed Smith following an unrelated murder investigation; Smith initially refused rights but later waived them after being warned and booked.
The interrogation produced no written statement or recording, but the officers testified Smith appeared coherent, answered questions logically, and waived rights.
Smith filed suppression motions; the trial court held a combined suppression hearing in February 2010 and overruled the motions.
On appeal, the court of appeals affirmed the trial court, ruling the statements were voluntary and the pleas knowingly, intelligently, and voluntarily entered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the Miranda-based confession involuntary?	Smith	State	Overruled; confession voluntary
Were Smith's pleas knowingly, intelligently, and voluntarily entered?	Smith	State	Overruled; pleas valid

Engle v. State, 74 Ohio St.3d 525 (Ohio 1996) (plea must be knowingly, intelligently, and voluntarily entered)
Treesh, 90 Ohio St.3d 460 (Ohio 2001) (totality of the circumstances standard for voluntariness)
Edwards, 49 Ohio St.2d 31 (Ohio 1976) (factors for determining voluntariness in confessions)
Clark, 38 Ohio St.3d 252 (Ohio 1988) (coercive interrogation factors and admissibility)
Perez, 124 Ohio St.3d 122 (Ohio 2009) (standards for determining voluntary waiver of Miranda rights)