State v. Walters, 2016 Ohio 5783

Defendant William M. Walters was charged with rape and sexual battery with a child-under-13 specification; he pleaded guilty to sexual battery (second-degree felony) and the specification; rape was dismissed under the plea agreement.
The charging statute (R.C. 2907.03(B)) required imposition of a mandatory prison term drawn from the second-degree felony range (2–8 years).
At plea hearing the court told Walters the maximum was eight years, there was a mandatory prison term, and Walters acknowledged understanding (including that minimum mandatory was two years); Walters signed a written plea form that also noted the maximum and a handwritten “minimum mandatory Two (2) years.”
Walters later moved to withdraw his plea (denied), and at sentencing the court imposed seven years and the entry described the term as “a mandatory stated prison term of Seven (7) years…with minimum mandatory Two (2) years.”
On appeal Walters argued (1) his plea was not knowingly, intelligently, and voluntarily made because the court did not adequately explain the maximum mandatory nature of the sentence (and judicial release ineligibility), and (2) the sentence was an unlawful “hybrid” of mandatory and discretionary time.
The Fourth District (Hoover, J.) affirmed the conviction (plea valid) but found plain error in sentencing and remanded for resentencing because the judgment entry suggested a prohibited hybrid sentence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Walters)	Held
Validity of guilty plea under Crim.R. 11(C)(2)(a)	Court substantially complied with Crim.R. 11; judge advised maximum and mandatory nature; defendant affirmed understanding	Plea was not knowing/voluntary because court failed to explain that the entire sentence was mandatory and that judicial release was unavailable; handwritten plea-form language confused him	Overruled Walters’ challenge; plea was knowing, voluntary, intelligent — trial court substantially complied with Crim.R. 11(C)(2)(a)
Legality of sentence (hybrid mandatory/discretionary term)	Sentence language was inartful but court intended a fully mandatory term; no discretionary component was actually imposed	Sentencing entry created a hybrid mandatory/discretionary term (seven years with a separate 2-year “minimum mandatory”), which is unlawful under Ware	Sustained; sentencing entry suggested an impermissible hybrid term; sentence contrary to law — remanded for resentencing (plain error found)

State v. Ware, 141 Ohio St.3d 160 (Ohio 2014) (trial courts may not divide a single statutorily‑mandated prison term into mandatory and discretionary subterms)
State v. Clark, 119 Ohio St.3d 239 (Ohio 2008) (distinguishes partial vs. complete noncompliance with Crim.R. 11 and explains prejudice test for nonconstitutional advisements)
State v. Veney, 120 Ohio St.3d 176 (Ohio 2008) (plea must be knowing, intelligent, and voluntary; appellate de novo review of compliance)
State v. Fischer, 128 Ohio St.3d 92 (Ohio 2010) (sentencing judges lack authority to impose sentences contrary to law)
State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (plain‑error framework and requirements under Crim.R. 52(B))