State v. Williams
2018 Ohio 1000
Ohio Ct. App.2018Background
- Kelley A. Williams appealed after pleading no contest in Toledo Municipal Court to failure to comply (R.C. 2921.331), a first-degree misdemeanor, and receiving a 180-day jail sentence.
- At the March 3, 2017 hearing, defense counsel stated there was a plea recommendation to amend charges in exchange for Williams' no contest plea.
- The trial court questioned Williams about why she failed to comply and why she drove without a license but did not inform her of the effect of her plea.
- Williams challenged the plea as involuntary and unknowing, arguing the court failed to comply with Crim.R. 11(E).
- The appellate court found a complete failure to advise Williams of the effect of her plea under Crim.R. 11(E), vacated the plea, reversed the conviction, and remanded for further proceedings; the sentencing claim was rendered moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the no contest plea was voluntary and knowing under Crim.R. 11(E) | State: court properly accepted plea under plea recommendation | Williams: court failed to inform her of plea's effect, violating Crim.R. 11(E) | Reversed: complete failure to advise of plea effect invalidates plea without prejudice showing |
| Whether the trial court abused discretion in imposing maximum sentence | State: sentence was permissible | Williams: maximum term was improper | Moot (plea vacated; sentencing claim not decided) |
Key Cases Cited
- State v. Jones, 116 Ohio St.3d 211 (court must inform defendant of effect of plea under Crim.R. 11(B) before accepting plea in petty-offense misdemeanor)
- State v. Clark, 119 Ohio St.3d 239 (complete failure to advise defendant of plea effect renders plea invalid without showing prejudice)