State v. Stubbs, 2014 Ohio 3696

Indicted September 6, 2012 in Franklin County for aggravated murder with a firearm specification arising from the shooting death of a woman who had rented him a room.
Appellant Jason L. Stubbs initially pleaded not guilty; competency evaluation ordered two months later found no serious mental illness and capacity to understand proceedings.
On May 21, 2013, Stubbs withdrew the not guilty plea and pled guilty to aggravated murder without a firearm specification; trial court accepted the plea and ordered a pre-sentence investigation.
On July 12, 2013, the trial court sentenced Stubbs to life imprisonment without the possibility of parole.
Appellant appealed, challenging (1) Crim.R. 11(C) compliance and the knowing, intelligent, and voluntary nature of the plea, and (2) the sentence as contrary to law or an abuse of discretion.
The appellate court affirmed, holding the plea was validly accepted and the sentence within statutory bounds; no reversible errors found.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the plea was knowingly, intelligently, and voluntarily made	Stubbs contends the court failed to determine he understood the charge.	Stubbs argues mental health status undermined understanding of the charge.	Plea valid; substantial compliance with Crim.R. 11; totality supports understanding.
Whether the life-without-parole sentence is contrary to law	Sentence weighed improper factors or mitigation; abuse of discretion.	Trial court could weighing factors; within statutory range.	Sentence within statutory guidelines; not contrary to law; no abuse of discretion.

State v. Akbari, 2013-Ohio-5709 (10th Dist. 2013) (Crim.R. 11(C) substantial compliance and knowingly understanding plea)
State v. Vinson, 2009-Ohio-3240 (10th Dist. 2009) (totality of circumstances may show understanding of charge)
State v. Rainey, 3 Ohio App.3d 441 (10th Dist.1982) (court may rely on totality of the circumstances for understanding)
State v. Staten, 2005-Ohio-6753 (10th Dist. 2005) (elements discussion not always required for waiver validity)
State v. Foster, 2012-Ohio-4129 (10th Dist. 2012) (sentencing procedures and factors in Ohio)