Twinsburg v. Milano, 110 N.E.3d 781

Jennifer Milano was arrested for domestic violence (first‑degree misdemeanor) after striking her boyfriend; she pleaded guilty at a video arraignment the next day without counsel.
The municipal court sentenced her to a fine and ten days (suspended) with community control.
Milano later moved to withdraw her guilty plea, attaching a partial transcript (full audio was lost) and an affidavit stating the court never advised her of the effect of the plea and that she would have retained counsel and not pled guilty if properly advised.
The trial court denied the motion, relying on the judge’s recollection that he had reviewed an acknowledgement/waiver form with Milano at the plea hearing.
The acknowledgement/waiver form in the record did not state that a guilty plea is a complete admission of guilt as required by Crim.R. 11(B)(1), and the preserved portion of the colloquy did not show the court informed her of the effect of the plea.
The appellate court reviewed whether the trial court complied with Crim.R. 11 in a petty‑misdemeanor plea and reversed, finding a complete lack of compliance concerning informing Milano of the effect of her plea.

Issue	Milano's Argument	Twinsburg/State's Argument	Held
Whether the trial court erred by denying Milano's post‑sentence motion to withdraw her guilty plea based on Crim.R. 11 noncompliance	Milano: plea involuntary/unknowing because court did not inform her of the effect of a guilty plea or her rights; she would have retained counsel and not pled guilty	Trial court/City: judge recalled reviewing the acknowledgement/waiver form with Milano and therefore complied with required advisements	Court: Reversed—complete failure to comply with Crim.R. 11(E)/(B) as to informing Milano that a guilty plea is a complete admission of guilt; plea must be vacated and matter remanded

State v. Xie, 62 Ohio St.3d 521 (Ohio 1992) (standard that guilty plea withdrawals rest within trial court discretion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse of discretion standard defined)
State v. Jones, 116 Ohio St.3d 211 (Ohio 2007) (Crim.R. 11 plea advisement requirements and that Crim.R. 11(B) language may be given orally or in writing)
State v. Clark, 119 Ohio St.3d 239 (Ohio 2008) (substantial compliance test and prejudice inquiry for nonconstitutional plea advisements)
State v. Nero, 56 Ohio St.3d 106 (Ohio 1990) (defendant must understand implications of plea)
State v. Griggs, 103 Ohio St.3d 85 (Ohio 2004) (nonconstitutional rights under Crim.R. 11 reviewed for substantial compliance)
State ex rel. Schneider v. Kreiner, 83 Ohio St.3d 203 (Ohio 1998) (definition of manifest injustice)