OHIO SUPREME COURT Justices rule guilty plea stands for Warren killer

Griggs robbed and fatally stabbed a man in 1999.
By MICHELE C. HLADIK
VINDICATOR CORRESPONDENT
COLUMBUS -- A Warren man knowingly gave up his rights to a trial when he pleaded guilty to voluntary manslaughter and burglary, the Ohio Supreme Court said in a unanimous decision released Wednesday.
Abraham A. Griggs was indicted by a Trumbull County grand jury on counts of aggravated murder, aggravated burglary and felonious assault for the 1999 robbery and fatal stabbing of 26-year-old Fred Taylor.
Plea bargain
Griggs originally pleaded innocent to all charges, but he later agreed to plead guilty to reduced charges of voluntary manslaughter and burglary.
Justice Maureen O'Connor pointed out Griggs' admission to the police that he had stabbed Taylor during a fight, and his acceptance of the offered guilty plea to charges of manslaughter and burglary in the decision.
"Griggs understood that by entering his guilty plea, he admitted to committing voluntary manslaughter and burglary," she wrote. "Accordingly, we hold that a defendant who has entered a guilty plea without asserting actual innocence is presumed to understand that he has completely admitted his guilt."
The state's high court said a trial court judge is required to make sure the defendant understands "the effects of his plea" and that he is giving up his rights to a trial before accepting a defendant's plea of guilty to a felony.
The court was considering whether Griggs knowingly and voluntarily gave up his rights to a trial with his plea.
The supreme court ruled that Trumbull County Court of Common Pleas judge talked with Griggs, informing him of the various constitutional rights he was giving up by pleading guilty, but did not specifically inform him that his guilty plea constituted a "complete admission of guilt."
10-year sentence
Griggs was sentenced to serve 10 years for voluntary manslaughter and eight years for burglary, with the sentences to be served concurrently.
He later filed an appeal asserting that his guilty plea was not made "knowingly and voluntarily" because the trial judge failed to specifically inform him his plea constituted "a complete admission of guilt."
The 11th District Court of Appeals denied the appeal, but admitted its ruling conflicted with a decision by the U.S. 2nd District Court of Appeals in a similar case.
"Under the substantial compliance standard, we review the totality of circumstances surrounding Griggs' plea and determine whether he subjectively understood that a guilty plea is a complete admission of guilt," wrote Justice O'Connor. "Here, Griggs pleaded guilty after he acknowledged voluntarily signing a document in which he stated that he committed the crimes of voluntary manslaughter and burglary. The court received assurances from Griggs and his counsel that Griggs understood the content of the document and the consequences of waiving his rights."
Justice O'Connor also pointed to a 1987 Ohio Supreme Court decision, in which the court stated "[a] plea of guilty is a complete admission of guilt."