State v. Stapleton, 2017 Ohio 1309

Defendant Michael Stapleton cared for six children on Nov. 29, 2015; four‑year‑old B.J. suffered severe blunt‑force injuries that later caused his death.
Stapleton was indicted on multiple counts including murder, felonious assault, endangering children, involuntary manslaughter, and possession of criminal tools.
While jailed, investigation revealed Stapleton had burglarized a relative’s home in early November, stealing a Hi‑Point handgun whose serial number he filed off.
On March 25, 2016 Stapleton pleaded guilty to one count of murder (as proximate result of endangering children) and to burglary under a bill of information; eight other counts were dismissed per plea agreement.
The trial court imposed consecutive sentences: 15 years to life for murder and 36 months for burglary, plus restitution, counsel fees, and costs.
Stapleton appealed, arguing (1) the plea colloquy did not satisfy Crim.R. 11 and (2) the trial court erred in imposing maximum consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea colloquy complied with Crim.R. 11(C)(2)	State: court properly informed defendant of constitutional rights and obtained understanding	Stapleton: court failed to advise he was entitled to presumption of innocence and of not having to call/prove witnesses at trial	Court affirmed: strict compliance with Crim.R. 11(C)(2)(c) shown; no rule requires stating presumption of innocence or obligation to call witnesses
Whether trial court erred by imposing maximum consecutive sentences under R.C. 2929.14(C)(4)	State: court considered R.C. 2929.11/2929.12, made required consecutive‑sentence findings and applied them to facts	Stapleton: court failed to weigh mitigating R.C. 2929.12 factors (remorse, limited record) and record doesn’t support consecutive sentences	Court affirmed: court made statutory findings in hearing and entry; findings supported by record; R.C. 2929.12 factors not required for consecutive findings

State v. Clark, 119 Ohio St.3d 239 (trial courts should literally comply with Crim.R. 11)
State v. Nero, 56 Ohio St.3d 106 (explaining substantial compliance standard for non‑constitutional Crim.R. 11 rights)
State v. Marcum, 146 Ohio St.3d 516 (standard of review under R.C. 2953.08(G)(2) for felony sentences)
State v. Mathis, 109 Ohio St.3d 54 (trial court must consider statutory sentencing criteria)
State v. Bonnell, 140 Ohio St.3d 209 (trial court must make statutory consecutive‑sentence findings and incorporate into entry)
State v. King, 992 N.E.2d 491 (trial court not required to state reasons for imposing maximum or greater‑than‑minimum sentences)