State v. Watkins

Summary

The Ohio Supreme Court held that when a defendant charged with a petty misdemeanor traffic offense enters a guilty or no-contest plea, Traf.R. 10(D) requires the court to inform the defendant of the effect of the plea as described in Traf.R. 10(B). The court rejected the argument that the trial court must conduct the more extensive constitutional-rights colloquy required for felony pleas under Crim.R. 11(C) and affirmed the judgment.

Holdings

1. When a defendant charged with a petty misdemeanor traffic offense pleads guilty or no contest, the trial court complies with Traf.R. 10(D) by informing the defendant of the information contained in Traf.R. 10(B); the court is not required to conduct the expanded rights colloquy required by Crim.R. 11(C) in felony cases.

Questions Presented

1. Whether a trial court accepting a guilty or no-contest plea to a petty misdemeanor traffic offense must conduct a colloquy substantially equivalent to the felony colloquy required by Crim.R. 11(C).
2. Whether informing the defendant of the information concerning the effect of the plea contained in Traf.R. 10(B) satisfies Traf.R. 10(D).

Disposition

affirmed