State ex rel. Cornwall v. Sutula (Slip Opinion), 71 N.E.3d 1020

In Feb. 2011 Cornwall pleaded guilty to gross sexual imposition with a sexually-violent-predator specification and was sentenced to 16 months plus five years of mandatory postrelease control.
In May 2014 he pleaded guilty to attempted failure to provide notice of change of address; the trial court sentenced him to 1 year for that offense and imposed an additional 2.5-year consecutive prison term for violating the existing postrelease control.
Cornwall did not appeal those sentences; he later filed a motion to correct a void sentence challenging the length of the postrelease-control sanction, which the trial court denied.
He then sought a writ of mandamus in the court of appeals asking the sentencing judge to vacate the postrelease-control sentence on the ground he had not been notified at his original sentencing of the possibility of a separate consecutive term under R.C. 2929.141(A).
The Eighth District granted the judge summary judgment; the Ohio Supreme Court affirmed, holding Cornwall had an adequate remedy at law (appeal) and therefore mandamus was unavailable, and declined to decide the substantive statutory-notice split among districts.

Issue	Cornwall's Argument	Sutula's Argument	Held
Whether a trial court must advise a defendant at initial sentencing that a later separate consecutive prison term may be imposed under R.C. 2929.141(A) if the defendant commits a felony while on postrelease control	Cornwall: Lack of that notice at the earlier sentencing renders a later R.C. 2929.141(A) consecutive term invalid	Sutula: Statutory postrelease-control notification requirements do not include the R.C. 2929.141(A) consequence; later courts retain authority to impose the separate term	Court did not decide the merits; noted districts are split and Eighth District precedent rejects Cornwall’s notice theory
Whether mandamus is an available remedy to vacate the postrelease-control sentence when Cornwall failed to appeal his sentences or earlier postconviction filings	Cornwall: Mandamus appropriate to obtain vacatur of the postrelease-control sentence	Sutula: An appeal (or direct challenge) was an adequate remedy in the ordinary course of law, so mandamus is unavailable	Held: Mandamus denied—Cornwall had an adequate remedy by appeal, so he cannot obtain relief by mandamus

State ex rel. Waters v. Spaeth, 960 N.E.2d 452 (Ohio 2012) (standards for mandamus and burden of proof)
State ex rel. Ward v. Reed, 21 N.E.3d 303 (Ohio 2014) (appeal is an adequate remedy that bars mandamus)
State ex rel. Crabtree v. Franklin Cty. Bd. of Health, 673 N.E.2d 1281 (Ohio 1997) (appeal as adequate remedy)
State ex rel. Sevayega v. McMonagle, 907 N.E.2d 1180 (Ohio 2009) (mandamus unavailable where adequate legal remedy exists)