State v. Yarochovitch, 92 N.E.3d 304

Appellant Oleh Yarochovitch and accomplices committed multiple burglaries; police linked them via license-plate footage and recovered victims’ property during searches.
Appellant reached a plea agreement and entered guilty pleas in three Cuyahoga County cases to various felonies (including multiple second-degree and fifth-degree felonies) on April 12, 2016.
At the plea hearing, the trial court did not inform appellant of mandatory postrelease control applicable to some convictions; the parties and appellate record concede this omission.
Sentencing on May 10, 2016 produced an aggregate prison term of 14 years and 11 months and entries imposing postrelease control, though the plea colloquy lacked advisement about postrelease control.
Appellant appealed, arguing his pleas were not knowing, voluntary, and intelligent because Crim.R. 11 advisements about postrelease control were not given; the state argued deportation or prior knowledge would negate prejudice.

Issue	State's Argument	Yarochovitch's Argument	Held
Whether the trial court’s failure at the plea colloquy to advise of postrelease control invalidates guilty pleas	Appellee: any lack of advisement caused no prejudice because appellant may be deported upon release and/or already knew about postrelease control from prior supervision	Appellant: complete omission of postrelease-control advisement means plea was not knowingly, intelligently, and voluntarily made under Crim.R. 11	Court vacated pleas and remanded because the trial court completely failed to advise of mandatory postrelease control as required by Crim.R. 11 and Sarkozy

State v. Engle, 74 Ohio St.3d 525 (1996) (plea must be knowingly, intelligently, and voluntarily made and court must comply with Crim.R. 11)
State v. Sarkozy, 117 Ohio St.3d 86 (2008) (trial court’s complete failure to advise of mandatory postrelease control requires vacating the plea and remanding)