State ex rel. Dobson v. Handwork (Slip Opinion), 151 N.E.3d 613

Andrew R. Schuman was convicted after a bench trial of seven felonies and sentenced to three years of community control that included a 45‑day jail term and a no‑contact condition.
At sentencing counsel requested a practice‑of‑law exception to the no‑contact condition; the judge said he would consider it but did not include such an exception in the judgment of sentence entered August 5, 2019.
Schuman filed a notice of appeal on August 7, 2019 and on the same day moved in the trial court to modify the judgment to add the practice‑of‑law exception; the judge later granted that motion (August 19) and then reduced the jail term (August 28).
Wood County Prosecuting Attorney Paul Dobson filed an original action for a writ of prohibition asking the Supreme Court to vacate the two postjudgment orders as beyond the trial court’s jurisdiction; Judge Handwork did not answer and Dobson moved for default judgment.
The Supreme Court granted default judgment, held the postjudgment orders void because the trial court lost jurisdiction once the appeal was filed (except to act in aid of the appeal), vacated the two orders, prohibited further exercise of jurisdiction except in aid of the appeal, and taxed costs to the judge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction to modify the judgment of sentence after Schuman filed a notice of appeal	Dobson: filing a notice of appeal divested the trial court of jurisdiction except to act in aid of the appeal; any modification was unauthorized	Schuman/Judge: moved for and the judge did grant modifications after appeal was filed (implicit position that trial court could act)	Court: Trial court lacked jurisdiction once appeal filed; the postjudgment modifications are void
Whether the trial‑court orders qualified as action “in aid of the appeal”	Dobson: orders altered the substance of the sentence and therefore were not in aid of the appeal	Judge: (implicit) orders addressed supervision/sentencing details and were proper to resolve	Court: Orders were not in aid of the appeal (they changed the substantive judgment)
Whether default judgment was appropriate under Civ.R. 55(D) against a judge who did not answer	Dobson: complaint and exhibits established his entitlement to relief under the rule; default judgment should be entered	Judge: no responsive pleading filed	Court: Default judgment granted because the verified complaint sufficiently proved Dobson’s right to relief

State v. Raber, 982 N.E.2d 684 (2012) (trial courts lack authority to reconsider final criminal judgments)
State ex rel. White v. Junkin, 686 N.E.2d 267 (1997) (same principle regarding reconsideration of final criminal judgments)
In re S.J., 829 N.E.2d 1207 (2005) (once a case is appealed, the trial court loses jurisdiction except to take action in aid of the appeal)
State ex rel. Greene Cty. Bd. of Commrs. v. O’Diam, 129 N.E.3d 393 (2019) (absence of jurisdiction that is patent and unambiguous dispenses with need to consider adequacy of alternative remedies)
Kostelnik v. Helper, 770 N.E.2d 58 (2002) (motions not expressly decided at termination of the case are ordinarily presumed overruled)
State ex rel. Special Prosecutors v. Judges of the Court of Common Pleas, 378 N.E.2d 162 (1978) (examples of matters that are "in aid of the appeal" are limited and do not include modification of the substantive judgment)