State v. Wallace, 132 N.E.3d 1317

Wallace was indicted on multiple felonies including aggravated burglary, aggravated robbery, and rape (each with firearm specifications); he later pled guilty to one count each of aggravated burglary, aggravated robbery, and rape with firearm specs; remaining counts were nolled.
A competency evaluation ordered after defense counsel's suggestion found Wallace competent; counsel stipulated to the report twice before the plea hearing.
At the plea hearing the court advised Wallace of maximum imprisonment and mandatory firearm terms, and accepted a joint recommendation of 20 years total (concurrent 11-year terms plus consecutive 3-year firearm terms).
The plea colloquy did not mention that a rape conviction would result in Tier III sex-offender classification with lifetime registration/verification and community-notification requirements; the written plea form also did not reference sex-offender consequences.
Wallace filed a delayed appeal and raised two assignments of error: (1) the rape plea was not knowing, intelligent, and voluntary because the court failed to advise on sex-offender consequences, and (2) the court failed to make an on-the-record competency finding.
The Tenth District affirmed in part and reversed in part: it vacated the rape plea for failure to comply with Crim.R. 11(C)(2)(a) as to sex-offender penalties, but rejected plain-error relief for lack of an explicit on-the-record competency finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea to rape was knowing/voluntary under Crim.R. 11 when court did not advise of Tier III consequences	State: imprisonment was the relevant "maximum penalty" and court satisfied Crim.R. 11 by advising of prison exposure; no oral advisal of sex-offender duties required	Wallace: Crim.R. 11(C)(2)(a) required the court to determine he understood the full penalty for rape, including Tier III registration/notification/verification	Court: Vacated rape plea — court completely failed to comply with Crim.R. 11(C)(2)(a) because it never addressed Tier III consequences and had no record basis to determine Wallace understood them
Whether court’s failure to make an explicit on-the-record competency finding was plain error	State: competency was established by examination and counsel’s stipulation; no manifest injustice	Wallace: trial court should have entered a formal competency finding on the record before accepting plea	Court: No plain error — competency evaluation found Wallace competent and counsel stipulated twice; no indicia of incompetence, so omission did not warrant reversal

State v. Veney, 120 Ohio St.3d 176 (2008) (distinguishes constitutional vs. nonconstitutional Crim.R. 11 requirements and requires strict compliance for constitutional protections)
State v. Clark, 119 Ohio St.3d 239 (2008) (complete failure to comply with Crim.R. 11 requires vacatur without a prejudice showing)
State v. Johnson, 40 Ohio St.3d 130 (1988) (Crim.R. 11's reference to "the maximum penalty" construed to mean the single-charge maximum, not cumulative exposure)
State v. Williams, 129 Ohio St.3d 344 (2011) (R.C. Chapter 2950 sex-offender scheme is punitive; sex-offender consequences are part of the penalty and must be addressed under Crim.R. 11)
State v. Sarkozy, 117 Ohio St.3d 86 (2008) (failure to comply fully with Crim.R. 11 constitutes a complete failure requiring vacatur)
State v. Bock, 28 Ohio St.3d 108 (1986) (failure to hold a mandatory competency hearing is harmless where record lacks indicia of incompetence)
State v. Palmer, 131 Ohio St.3d 278 (2012) (Tier III classification requires registration every 90 days for life and community notification)