State v. Wyatt, 2017 Ohio 8319

Paul A. Wyatt, III faced multiple indictments across three Cuyahoga County cases; relevant here he pleaded guilty in CR-16-609331-A to aggravated robbery with a one-year firearm specification and carrying a concealed weapon (with forfeiture), as part of a plea bargain.
A substitute judge, with defense counsel’s assent, accepted Wyatt’s guilty pleas on behalf of the assigned judge after a brief plea colloquy.
The court explained the sentencing ranges for aggravated robbery (first-degree felony, 3–11 years) and the one-year firearm specification would be served in addition to the base term; Wyatt asked clarifying questions and responded that he understood.
At combined sentencing the court imposed an aggregate five-year prison term in CR-16-609331-A (including the one-year firearm specification) to be served concurrently with sentences in the other cases.
On appeal Wyatt argued his pleas were not knowing, intelligent, or voluntary because the trial court failed to expressly tell him he faced a mandatory minimum four-year prison term (3 years for the base offense + 1 year firearm spec).
The Eighth District affirmed, finding the court substantially complied with Crim.R. 11(C)(2)(a) and that, under the totality of the circumstances, Wyatt understood the mandatory nature of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with Crim.R. 11(C)(2)(a) in advising Wyatt of a mandatory prison sentence	State: Court substantially complied with Crim.R. 11 by explaining the base-range and that the one-year firearm specification is served in addition to the base term; Wyatt showed he understood	Wyatt: Court failed to expressly state he faced a mandatory minimum four-year term or that he was ineligible for community control, so plea was not knowing, intelligent, voluntary	Court: Substantial compliance satisfied; totality of circumstances show Wyatt understood the added one-year spec and the base range, so no prejudice and plea affirmed

State v. Veney, 120 Ohio St.3d 176 (2008) (distinguishes strict compliance for constitutional rights from substantial compliance for nonconstitutional Crim.R. 11 advisements)
State v. Stewart, 51 Ohio St.2d 86 (1977) (discusses Crim.R. 11 substantial compliance standard)
State v. Nero, 56 Ohio St.3d 106 (1990) (explains subjective-understanding test for substantial compliance)
State v. Clark, 119 Ohio St.3d 239 (2008) (clarifies partial vs. complete failure to comply and prejudice analysis)
State v. Sarkozy, 117 Ohio St.3d 86 (2008) (addresses consequences of complete failure to comply with Crim.R. 11)