State v. Aarons, 2021 Ohio 3671

Defendant Richard Aarons pleaded guilty pursuant to a plea deal to one count of drug possession (C.P. No. CR-18-629018-A) and to involuntary manslaughter, failure to comply with police, and one DUI misdemeanor (C.P. No. CR-19-643581-A).
At sentencing (Jan. 25, 2021) the court announced an aggregate Reagan Tokes indefinite sentence of 8 to 11 years (6 years minimum on Count 1 + 2 years consecutive on Count 4), and discussed credit for time served on the misdemeanor; the court also referenced five years mandatory post-release control.
The trial court’s Jan. 27, 2021 journal entry described an 8-year indefinite sentence but did not set separate, count-by-count sentences (i.e., a “blanket” sentence).
Aarons filed a notice of appeal (Feb. 24, 2021). After the appeal was filed the trial court issued multiple “corrected” journal entries (Apr. 6, Apr. 7, June 11, 2021) attempting to set per-count sentences and to change the stated maximum.
The appellate court held the original journal entry was not a final, appealable order because it failed to set separate sentences for each count, and concluded the trial court lacked jurisdiction to issue the post-appeal "corrected" entries; the corrections were void, and the appeal was dismissed for lack of jurisdiction. The companion appeal in CR-629018 was also dismissed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Aarons)	Held
1) Did the trial court retain jurisdiction to issue corrected sentencing journal entries after notice of appeal?	State agreed remand for resentencing was appropriate.	Court lacked jurisdiction to amend journal entries after appeal; corrections are void.	The original entry was not final (blanket sentence); trial court was divested of jurisdiction after appeal; post-appeal corrections were void; appeal dismissed for lack of jurisdiction.
2) Is the Reagan Tokes Act unconstitutional as applied to Aarons?	State did not contest sentencing authority; suggested remand.	Aarons argued Reagan Tokes violates U.S. and Ohio Constitutions.	Not reached on merits—claims rendered moot by dismissal for lack of jurisdiction.
3) Did Aarons receive ineffective assistance for failing to challenge the Reagan Tokes Act?	State did not press this claim in light of jurisdictional posture.	Counsel failed to challenge the constitutionality of Reagan Tokes, violating Sixth Amendment.	Not reached—claim was moot because appeal dismissed for lack of jurisdiction.
4) Was the sentence contrary to law or outside the proper range?	State sought remand/resentencing.	Aarons contended sentencing entries were legally defective (Reagan Tokes errors, aggregate discrepancies).	Court dismissed appeal for lack of jurisdiction; substantive sentencing challenges not decided.

State v. Lester, 958 N.E.2d 142 (Ohio 2011) (elements required for a final, appealable judgment of conviction)
State v. Craig, 151 N.E.3d 574 (Ohio 2020) (a sentencing entry must fully resolve all counts to be final)
State v. Jackson, 87 N.E.3d 1227 (Ohio 2017) (valid judgment of conviction requires full resolution of convicted counts)
State v. Saxon, 846 N.E.2d 824 (Ohio 2006) (trial court must impose separate sentence for each offense)
State v. Miller, 940 N.E.2d 924 (Ohio 2010) (definition and limits of clerical mistakes and proper use of Crim.R. 36/nunc pro tunc)
State ex rel. Electronic Classroom of Tomorrow v. Cuyahoga Cty. Court of Common Pleas, 950 N.E.2d 149 (Ohio 2011) (filing a notice of appeal divests the trial court of jurisdiction except to act in aid of appeal)
State ex rel. Special Prosecutors v. Judges, Court of Common Pleas, 378 N.E.2d 162 (Ohio 1978) (post-appeal corrections inconsistent with appellate review are impermissible)