State ex rel. Love v. O'Donnell (Slip Opinion), 150 Ohio St. 3d 378

Michael K. Love was convicted of felony murder based on a predicate felonious-assault offense and was sentenced in Lake County Common Pleas Court.
Love contends the jury did not sign the verdict forms for the predicate felonious-assault offense underlying the felony-murder conviction.
He filed a mandamus petition asking the trial judge, John O’Donnell, to vacate the sentence and issue a new judgment entry, arguing the felony-murder sentence is void because the jury failed to find the predicate offense.
To obtain mandamus, Love must show a clear legal right to relief, a clear legal duty by the judge, and lack of an adequate remedy at law.
Love previously appealed his conviction but did not raise the verdict-form challenge on direct appeal; he later raised similar claims in postconviction motions, which were denied.
The Eleventh District dismissed the mandamus petition; the Supreme Court of Ohio affirmed, holding Love had an adequate remedy by appeal and that res judicata barred his claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury’s alleged failure to sign verdict forms for the predicate felonious-assault offense rendered Love’s felony-murder sentence void	Love: Jury failed to sign the predicate-offense verdict forms, so conviction/sentence for felony murder is void	Judge/Opposition: Sentencing or verdict-form defects do not necessarily divest the court of jurisdiction; Love had an adequate remedy by appeal and already litigated related claims	Court: Defect asserted is a sentencing/verdict-form issue — not a patent jurisdictional defect; Love had an adequate remedy by direct appeal and the claim is barred by res judicata
Whether mandamus is an appropriate remedy for Love’s claim	Love: Mandamus necessary because sentence is void and judge must vacate and reissue sentence	Judge: Mandamus inappropriate because Love had and used appellate and postconviction remedies; jurisdictional defect not established	Court: Mandamus denied — Love failed to show clear right, judge had no clear duty to grant relief, and adequate remedies existed

State ex rel. Waters v. Spaeth, 960 N.E.2d 452 (Ohio 2012) (elements required for mandamus relief)
State ex rel. Pruitt v. Donnelly, 954 N.E.2d 117 (Ohio 2011) (sentencing errors that are not patent jurisdictional defects do not divest court of power to enter judgment)
State ex rel. Plant v. Cosgrove, 893 N.E.2d 485 (Ohio 2008) (party contesting jurisdiction has adequate remedy by appeal absent patent lack of jurisdiction)
Shoop v. State, 43 N.E.3d 432 (Ohio 2015) (appeal is generally an adequate remedy barring mandamus)
State ex rel. Robinson v. Huron Cty. Court of Common Pleas, 34 N.E.3d 903 (Ohio 2015) (res judicata requires presenting every ground for relief in first action)
State ex rel. Pressley v. Indus. Comm., 228 N.E.2d 631 (Ohio 1967) (appeal ordinarily an adequate legal remedy)