State ex rel. Ward v. Reed (Slip Opinion), 141 Ohio St. 3d 50

Ward was convicted in 1997 of aggravated robbery and abduction with firearm specifications; direct appeal affirmed.
In 2012 Ward challenged his sentence for improper postrelease-control advisement; the trial court corrected the sentencing entry nunc pro tunc under R.C. 2929.191.
Ward filed mandamus and procedendo petitions seeking a final, appealable order from Judge Reed.
Judge Reed argued the original judgment complied with Crim.R. 32(C) and the nunc pro tunc correction did not need to be a separate final order.
The Third District held the corrected sentencing judgment, properly altered by nunc pro tunc entry, was final and appealable; extraordinary writs not warranted.
This Court affirmed, holding Ward had an adequate ordinary-course remedy by appeal, precluding mandamus and procedendo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ward had an adequate ordinary remedy by appeal precluding writs	Ward contends the nunc pro tunc entry is not a final, appealable order	The corrected sentence constitutes a final order; an appeal is adequate remedy	Yes; Ward had an adequate remedy by appeal precluding writs

State v. Baker, 119 Ohio St.3d 197 (2008-Ohio-3330) (final, appealable order requirements under Crim.R. 32(C) stressed)
Culgan v. Medina Cty. C.P., 119 Ohio St.3d 535 (2008-Ohio-4609) (same finality standard as Baker; use in mandamus context)
State ex rel. Sherrills v. Cuyahoga Cty. C.P., 72 Ohio St.3d 461 (1995) (mandamus/procedendo requirements)
State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55 (2012-Ohio-69) (clear right and duty; adequate-remedy requirement)
State ex rel. Crabtree v. Franklin Cty. Bd. of Health, 77 Ohio St.3d 247 (1997) (adequate remedy by appeal precludes extraordinary writs)
Sevayega v. McMonagle, 122 Ohio St.3d 54 (2009-Ohio-2367) (precludes writs where ordinary remedy exists)