State v. Woodall
2016 Ohio 294
Ohio Ct. App.2016Background
- Anthony Woodall was charged in three consolidated Cuyahoga County cases; this appeal concerns CR-13-577633-A only.
- In CR-13-577633-A Woodall faced multiple counts including trafficking and possession; under a plea agreement he agreed to plead guilty to Counts 1, 4, and 7 (all fifth-degree trafficking felonies) and forfeit certain property.
- During the plea colloquy the prosecutor and court described the plea as to Counts 1, 4, and 7, but the court misspoke intermittently, once referring to Count 5 instead of Count 4 and once reading Counts 1, 5, and 7.
- Defense counsel immediately corrected the court’s misstatement and the court promptly clarified that Woodall pleaded to Counts 1, 4, and 7; the journal entry reflected Counts 1, 4, and 7.
- Woodall was represented by counsel, did not object at trial, and was later sentenced to a combined 12 months across the cases; he appealed only the alleged error as to Count 4.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in finding Woodall guilty of Count 4 when it once misstated Count 5 during the plea | State: Plea colloquy and journal entry show defendant knowingly pleaded to Count 4; misstatement was isolated and corrected | Woodall: Court accepted plea to Count 5 (misstated) though he never actually pled to that count | No plain error; plea valid. Court corrected the misstatement, defendant was informed, represented, and journal reflects Counts 1, 4, and 7 |
Key Cases Cited
- State v. Cooperrider, 4 Ohio St.3d 226 (plain error doctrine should be invoked only in exceptional circumstances)
- State v. Kelley, 57 Ohio St.3d 127 (trial court must ensure plea is knowing and voluntary)
- State v. Ballard, 66 Ohio St.2d 473 (Crim.R. 11 requires meaningful dialogue reasonably intelligible to defendant)
- State v. Griggs, 103 Ohio St.3d 85 (failure to inform of constitutional rights presumes plea involuntary)
- Henderson v. Morgan, 426 U.S. 637 (defendant must have real notice of the true nature of the charge)
- Smith v. O’Grady, 312 U.S. 329 (due process requires notice of the charge)
- State v. Johnson, 40 Ohio St.3d 130 (Crim.R. 11(C)(2)(a) requires explanation of the nature of the charge)