State ex rel. Harris v. Hamilton Cty. Clerk of Courts (Slip Opinion), 2022 Ohio 477

In 1992 Lionel Harris was convicted of aggravated murder; Judge Donald Schott pronounced sentence in open court as “life imprisonment with parole eligible after serving 20 years and $25,000.”
The written sentencing entry was signed by Judge Thomas Nurre (on behalf of Judge Schott) and recited: life with parole eligibility after 20 years, pay costs, and a $25,000 fine.
In 2013 Harris challenged the validity of the entry when signed by Judge Nurre; this court held that signing a correctly worded entry is a ministerial act and did not void the sentence.
In 2021 Harris filed a mandamus petition seeking (1) vacatur and resentencing on the ground the written entry imposed costs/fine not pronounced by Judge Schott, and (2) return of funds paid as fines/costs.
The common pleas court and clerk moved to dismiss; the First District dismissed Harris’s petition and this Court affirmed, holding Harris had not shown his sentence was void or that mandamus was appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether written entry’s costs/fine not pronounced at sentencing render the entire sentence void	Harris: Costs and $25,000 fine were not validly imposed because Judge Schott did not pronounce them	Appellees: Entry signed by assigned judge is ministerial; any inconsistency does not deprive court of jurisdiction	Court: Inconsistency would make the sentence voidable, not void; not a jurisdictional defect
Whether mandamus can compel vacatur/resentencing and refund of payments	Harris: Seeks extraordinary writ to vacate sentence and recover funds because entry is inconsistent with oral sentence	Appellees: Mandamus requires a clear legal right and a void sentence; ordinary remedies and appeals cover sentencing errors	Court: Mandamus not available for non-jurisdictional sentencing errors; dismissal affirmed
What makes a sentence void for purposes of collateral extraordinary relief	Harris: Implied that sentencing entry defects render sentence void	Appellees: A sentence is void only if court lacked subject-matter or personal jurisdiction	Court: Agrees with authority that only jurisdictional defects render a sentence void; non-jurisdictional errors are voidable

State ex rel. Harris v. Hamilton Cty. Court of Common Pleas, 9 N.E.3d 1057 (Ohio 2014) (signing a judgment entry by an assigned judge is ministerial when the entry accurately reflects the pronounced sentence)
State v. Harper, 159 N.E.3d 248 (Ohio 2020) (a sentence is void only if the sentencing court lacked subject-matter or personal jurisdiction)
State v. Henderson, 162 N.E.3d 776 (Ohio 2020) (plurality: sentencing errors that occur despite jurisdiction render sentences voidable, not void)
State ex rel. Crangle v. Summit Cty. Common Pleas Court, 165 N.E.3d 1250 (Ohio 2020) (mandamus is not the proper vehicle to challenge non-jurisdictional sentencing errors)