State v. Sobczak, 2019 Ohio 330

Jennifer Sobczak pleaded guilty in March 2016 to one count of obstructing official business (2nd-degree misdemeanor); other charges were dismissed per plea agreement.
Sentence: $100 fine + costs; 90 days jail suspended on conditions (30 hours community service and no law violations for one year); plea included persona non grata restriction from Mantua PD.
State moved in June 2017 to impose the suspended sentence, alleging Sobczak violated conditions on October 2, 2016 (resisting arrest and obstructing).
Sobczak moved (through counsel and later pro se) to withdraw her guilty plea; the trial court denied the motion and, on January 23, 2018, orally denied her pro se motions and imposed 10 days of the previously suspended sentence (which she served).
Sobczak appealed; appointed appellate counsel filed an Anders brief; new counsel filed a merit brief arguing the trial court abused its discretion by denying withdrawal of plea.
The State moved to dismiss the appeal as moot because Sobczak had served the 10 days, completed the time windows for community service/fine payment had expired, and the one-year no-violation period elapsed before appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is moot because the sentence and conditions were satisfied	Appeal is moot: Sobczak served the imposed 10 days, statutory windows expired, and no collateral legal disability is shown	Appeal should proceed; alleged breach of plea (persona non grata status) hinders volunteering at PD and shows need for relief	Appeal dismissed as moot; no collateral legal disability shown and no stay was requested
Whether the trial court erred in denying motion to withdraw guilty plea after sentencing	State opposed withdrawal; maintained plea and sentencing were proper	Sobczak argued counsel lacked time to investigate and plea was involuntary/coerced; trial court abused discretion in denying withdrawal	Court did not reach merits of plea-withdrawal claim because appeal was moot

State v. Golston, 71 Ohio St.3d 224 (1994) (an appeal from a voluntarily satisfied misdemeanor judgment is moot absent evidence of collateral legal disability)
State v. Wilson, 41 Ohio St.2d 236 (1975) (mootness principles applied when sentence has been satisfied)
State v. Berndt, 29 Ohio St.3d 3 (1987) (court of appeals should dismiss moot criminal appeals where sentence was satisfied)
Cleveland Hts. v. Lewis, 129 Ohio St.3d 389 (2011) (reversible error to decide merits of a criminal appeal that became moot after defendant voluntarily satisfied sentence)
In re S.J.K., 114 Ohio St.3d 23 (2007) (definition of “collateral disability” as adverse legal consequences that survive satisfaction of sentence)