State v. Stafford

Summary

The Ninth District Court of Appeals of Ohio reversed Deshawn Stafford’s conviction and remanded the case for further proceedings. The court held that the guilty plea was invalid because the trial court failed to strictly comply with Crim.R. 11(C)(2)(c) by not advising Stafford that he was waiving the right to require the State to prove guilt beyond a reasonable doubt.

Holdings

1. A trial court must strictly comply with Crim.R. 11(C)(2)(c) by advising a defendant that a guilty plea waives the right to require the State to prove guilt beyond a reasonable doubt. The trial court's failure to include the beyond-a-reasonable-doubt standard made Stafford's guilty plea invalid.

Questions Presented

1. Whether Stafford's felony guilty plea was invalid because the trial court failed to advise him that the plea waived his right to require the State to prove his guilt beyond a reasonable doubt.
2. Whether the trial court adequately advised Stafford of the maximum sentence under the Reagan Tokes Act.

Disposition

reversed_and_remanded