State v. Ratliff

Ohio Court of Appeals·Decided July 6, 2026·No. 4-25-18·Published

Opinion

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT

DEFIANCE COUNTY

STATE OF OHIO, CASE NO. 4-25-18

PLAINTIFF-APPELLEE,

v.

DAVID J. RATLIFF, OPINION AND JUDGMENT ENTRY

DEFENDANT-APPELLANT.

Appeal from Defiance County Common Pleas Court Trial Court No. 24 CR 15421

Judgment Affirmed

Date of Decision: July 6, 2026

APPEARANCES:

Henry Schaefer for Appellant Russell R. Herman for Appellee

MILLER, J.

{¶1} Defendant-appellant, David J. Ratliff (“Ratliff”), brings this appeal from the judgment of the Defiance County Common Pleas Court accepting his Alford plea, finding him guilty of a single count of sexual battery, imposing a 12-month sentence and finding him to be a Tier III sexual offender. On appeal, Ratliff contends his Alford plea was not entered knowingly, voluntarily, or intelligently due to an inadequate colloquy with the trial judge.

Procedural History

{¶2} On April 24, 2024, Ratliff was indicted by the Defiance County grand jury on one count of rape in violation of R.C. 2907.02(A)(2), a first-degree felony, and one count of kidnapping in violation of R.C. 2905.01(A)(4), a second-degree felony. The charges stemmed from an incident that occurred on June 2, 2011. On that date, the victim reported to the hospital claiming she was kidnapped and raped by an unknown male. A rape examination was completed, and DNA was collected from a vaginal swab. The perpetrator remained unknown until 2017 when the Defiance Police Department was notified of a CODIS match with Ratliff of the DNA collected from the unkown male during the original investigation. In 2024, the victim was located and the case was presented to the grand jury. Shortly thereafter, Ratliff was arrested on the indictment. He entered pleas of not guilty at his arraignment on May 8, 2024. Ratliff remained in custody for the duration of the case.

{¶3} Over the course of the ensuing sixteen months, the case proceeded with numerous pretrial conferences and proceedings, including two changes of attorneys. The

matter came on for a jury trial on September 15, 2025. However, just prior to jury selection, the parties entered into a negotiated resolution with Ratliff agreeing to enter an Alford plea of guilty to a bill of information charging a single count of sexual battery in violation of R.C. 2907.03(A)(1), a third-degree felony. In exchange for Ratliff’s plea to the bill of information, the State agreed to recommend a 12-month term of incarceration with credit for time already served and to seek dismissal of the indictment with its two charges.

{¶4} The trial court proceeded to arraign Ratliff on the new charge at which time the court engaged in a lengthy plea colloquy. Ratliff tendered an Alford guilty plea which the court accepted. The trial court found him guilty and proceeded directly to sentencing. The court adopted the parties’ sentence recommendation of 12 months of incarceration with credit for the full term already served. Additionally, the trial court found Ratliff to be a Tier III sexual offender. The court also dismissed the rape and kidnapping charges. Ratliff filed a timely appeal raising one assignment of error.

Assignment of Error

The trial court erred in accepting Appellant’s Alford guilty plea as knowing, voluntary, and intelligent in violation of Crim.R. 11.

{¶5} Ratliff’s assignment of error challenges the three criteria for entering a change of plea. Specifically, he alleges his plea was not knowingly, voluntarily, and intelligently given. While Ratliff admits the trial court strictly complied with Crim.R. 11 in providing the constitutional advisements, he contends the court failed to “probe the non-constitutional voluntariness of the plea” after he expressed confusion.

Relevant Law

{¶6} The decision by a defendant to enter a guilty plea must be knowing, intelligent, and voluntary. State v. Dangler, 2020-Ohio-2765, ¶ 10. This is equally true for an Alford plea. See, e.g., State v. Padgett, 67 Ohio App.3d 332, 337-338 (2d Dist. 1990), construing Crim.R. 11(C). “Failure on any of those points renders enforcement of the plea unconstitutional under both the United States Constitution and the Ohio Constitution.” State v. Engle, 74 Ohio St.3d 525, 527 (1996). The trial court has the burden to ensure a defendant’s plea is voluntary and that the defendant understands the charges, the maximum penalty involved, and the effect of the plea, including its effect on the defendant’s rights. State v. Gowdy, 2025-Ohio-5575, ¶ 18, citing Crim.R. 11(C)(2).

{¶7} Crim.R. 11(C)(2) sets forth what a trial court is to communicate to the defendant at change-of-plea hearings and reads as follows:

(2) In felony cases the court may refuse to accept a plea of guilty or a plea of no contest, and shall not accept a plea of guilty or no contest without first addressing the defendant personally either in-person or by remote contemporaneous video in conformity with Crim.R. 43(A) and doing all of the following:

(a) Determining that the defendant is making the plea voluntarily, with understanding of the nature of the charges and of the maximum penalty involved, and if applicable, that the defendant is not eligible for probation or for the imposition of community control sanctions at the sentencing hearing.

(b) Informing the defendant of and determining that the defendant understands the effect of the plea of guilty or no contest, and that the court, upon acceptance of the plea, may proceed with judgment and sentence.

(c) Informing the defendant and determining that the defendant understands that by the plea the defendant is waiving the rights to jury trial, to confront witnesses against him or her, to have compulsory process for obtaining witnesses in the defendant’s favor, and to require the state to prove the defendant’s guilt beyond a reasonable doubt at a trial at which the defendant cannot be compelled to testify against himself or herself.

{¶8} Additionally, “[a]n ‘Alford plea’ is a specialized type of guilty plea when the defendant, although pleading guilty, continues to deny his or her guilt but enters the guilty plea because the defendant believes that the offered sentence is better than what the outcome of a trial is likely to be.” State v. Carey, 2011-Ohio-1998, ¶ 6 (3d Dist.), quoting State v. Schmidt, 2010-Ohio-4809, ¶13 (3d Dist.). “‘Because an Alford plea involves a rational calculation that is significantly different from the calculation made by a defendant who admits he is guilty, the obligation of the trial judge with respect to the taking of an Alford plea is correspondingly different.’” State v. Bolin, 2022-Ohio-3777, ¶ 6 (3d Dist.), quoting Padgett, at 338. Even though an Alford plea allows a defendant to maintain his factual innocence, the plea has the same legal effect as a guilty plea. State v. Vogelsong, 2007-Ohio-4935, ¶ 15 (3d Dist.).

{¶9} This Court has previously addressed the requirements for an Alford plea to be knowing, intelligent, and voluntary:

“In order for the trial court to establish that an Alford plea is knowing, voluntary, and intelligent, the court must conduct what is commonly referred to as an ‘Alford inquiry.’ An ‘Alford inquiry’ requires that the trial court question the defendant concerning the reasons for deciding to plead guilty, notwithstanding the protestations of innocence. The record also must contain strong evidence of guilt before an Alford plea may be accepted. Therefore,

the plea should not be made without the presentation of some basic facts surrounding the offenses charged.

(Citations omitted.) Bolin at ¶ 6, quoting State v. Scott, 2001-Ohio-2098, *5 (3d Dist.).

Standard of Review

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Related

State v. Carey
2011 Ohio 1998 (Ohio Court of Appeals, 2011)
State v. Schmidt
2010 Ohio 4809 (Ohio Court of Appeals, 2010)
State v. Vogelsong, 5-06-60 (9-24-2007)
2007 Ohio 4935 (Ohio Court of Appeals, 2007)
State v. Padgett
586 N.E.2d 1194 (Ohio Court of Appeals, 1990)
State v. Dangler (Slip Opinion)
2020 Ohio 2765 (Ohio Supreme Court, 2020)
State v. Alvarez
2020 Ohio 5183 (Ohio Court of Appeals, 2020)
State v. Engle
660 N.E.2d 450 (Ohio Supreme Court, 1996)
State v. Bolin
2022 Ohio 3777 (Ohio Court of Appeals, 2022)
State v. Nichols
2024 Ohio 5530 (Ohio Court of Appeals, 2024)
State v. Rayle
2025 Ohio 1912 (Ohio Court of Appeals, 2025)
State v. Gowdy
2025 Ohio 5575 (Ohio Supreme Court, 2025)