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No Contest, Guilty, And What Survives

Ohio Crim.R. 11 and 12 — the plea is a choice about what carries forward

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There are three pleas and the difference between them is not about how much remorse anybody is showing. It is about what carries forward out of the courtroom. Two of the three admit something, and only one of them closes the door behind it.

The pleaWhat it admitsWhat it leaves standing
Not guiltyNothingEverything, a trial included
No contestNot guilt, but the truth of the facts alleged in the indictment, information or complaintA pretrial ruling can still be appealed, and the plea is generally not usable against the person later
GuiltyGuilt, completelyThe ruling on the search goes with it
A guilty plea takes the suppression ruling with it. Crim.R. 12(I) says the plea of no contest does not preclude a defendant from asserting on appeal that the trial court prejudicially erred in ruling on a pretrial motion, a motion to suppress evidence included. Read the sentence backwards and it describes what a guilty plea does instead. Months of argument about whether a search was lawful can end in a ruling no court above the trial judge ever reads.

The other half of the no contest plea is about the rest of a person's life rather than the appeal. Crim.R. 11(B)(2) says the plea, and the admission inside it, shall not be used against the defendant in any subsequent civil or criminal proceeding. Where one event carries both a charge and a lawsuit, the two pleas are not interchangeable and the rule is the reason.

That protection has a hole in it the rule does not mention. In 2012 the Ohio Supreme Court held that neither Crim.R. 11(B)(2) nor Evid.R. 410(A)(2) stops the state from using a no contest plea in a later proceeding where the defendant is collaterally attacking the conviction the plea produced, a habeas action among them. The shield runs against the world. It does not run against the person's own attack on the judgment.
  • A plea of no contest to a misdemeanour constitutes an admission of the truth of the facts alleged in the complaint.
  • The judge or magistrate may make a finding of guilty or not guilty from the explanation of the circumstances of the offence.
  • Where the offence is a minor misdemeanour the judge or magistrate is not required to call for that explanation, and may base a finding on the facts alleged in the complaint.
The explanation is a real step, and the court has said what it is not. In Girard v. Giordano a court took a no contest plea to cruelty to animals and found the defendant guilty without ever calling for the explanation of circumstances. The Ohio Supreme Court held the explanation is a procedural protection rather than a measure of the sufficiency of the evidence, so the missing step does not end the prosecution. It reversed the discharge the court of appeals had ordered and sent the case back.
  • After imposing sentence in a serious offence case that went to trial, the court advises the defendant of the right to appeal.
  • It also advises that a defendant who cannot pay proceeds without payment, that counsel is appointed on request, and that the necessary documents come at no cost.
  • A notice of appeal from an order that is final on its entry is filed within thirty days of that entry.
  • Past the thirty days, a criminal defendant may seek leave for a delayed appeal, and the motion has to set out why the appeal as of right was never perfected.

Before I enter anything, which plea keeps the ruling on the motion to suppress appealable?

Which plea fits a particular case is the definition of legal advice and this section does not answer it. What is here is what each plea admits and what each one leaves behind under the statewide rules. What the trade is actually worth on one set of facts is a question for a licensed Ohio attorney, before anything is entered.

Sources for this section (9)
  1. Ohio Crim.R. 11Pleas, and what each one admits
  2. Ohio Crim.R. 12Pretrial motions, including motions to suppress evidence
  3. ORC 2937.07Plea of no contest, and the explanation of circumstances
  4. Ohio Evid.R. 410Inadmissibility of pleas, plea discussions, and related statements
  5. Hollingsworth v. Timmerman-Cooper, 133 Ohio St.3d 253, 2012-Ohio-3907The bar on using a no contest plea in a later proceeding does not reach the defendant's own collateral attack on the conviction
  6. Girard v. Giordano, 155 Ohio St.3d 470, 2018-Ohio-5024The explanation of circumstances is a procedural protection, not a measure of the sufficiency of the evidence
  7. Ohio Crim.R. 32Sentence, and the advice about appeal that follows it
  8. Ohio App.R. 4Appeal as of right, and the thirty days it has to be filed in
  9. Ohio App.R. 5Appeals by leave of court in criminal cases, after the thirty days have run

Legal information, not legal advice. Verified as of September 2026. Talk to a licensed Ohio attorney about your situation.

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