State ex rel. Beechler v. Rastatter (Slip Opinion), 18 N.E.3d 433

Beechler was convicted in 2009 of two felony OVI counts with a 5-or-more prior offenses specification within 20 years; the two counts were merged and sentenced to 5 years for the second count plus 5 years for the specification, consecutive.
The convictions and sentence were appealed and affirmed.
Beechler sought mandamus in 2013 to void the sentencing entry and halt litigation until vacated.
The Second District dismissed for lack of mandamus, citing adequate legal remedies by appeal.
Beechler appealed to the Ohio Supreme Court claiming the sentencing specification was void for not proving five felony OVI priors within 20 years; issue centers on R.C. 2941.1413's “equivalent offenses” concept.
The Supreme Court affirmed the court of appeals, holding Beechler had an adequate remedy at law and that the statute allows non-felony equivalent offenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus was proper given an adequate remedy at law by appeal.	Beechler argues mandamus is needed to challenge void sentencing.	Rastatter argues appellate remedies suffice.	No mandamus; adequate remedy exists.

State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55 (Ohio Supreme Court 2012) (mandamus standard and necessity of clear rights/duties; adequate remedy at law)
State ex rel. Nickleson v. Mayberry, 131 Ohio St.3d 416 (Ohio Supreme Court 2012) (adequate remedies at law; issues reviewable on appeal)