State v. Alexander, 2020 Ohio 3838

Appellant Juwuan Alexander pled guilty to one count of aggravated robbery for brandishing a .40 Glock and stealing a PlayStation and games from a victim's home on May 1, 2019.
Plea colloquy and sentencing proceeded under the recently enacted Reagan Tokes Law (R.C. 2967.271), which creates an indefinite postrelease-review structure allowing the DRC to extend incarceration beyond a judicially imposed minimum.
At plea, the court explained the sentencing scheme and gave examples of minimums and potential extensions; Alexander acknowledged understanding the explanation.
At sentencing the court imposed an indefinite term of 8 to 12 years (8-year minimum, 12-year maximum) under the Reagan Tokes framework; Alexander did not object or raise a constitutional challenge in the trial court.
On appeal Alexander argued R.C. 2967.271 is unconstitutional because it permits prison officials, not the sentencing court, to justify additional incarceration, violating due process.
The Twelfth District held Alexander forfeited the constitutional challenge by failing to raise it in the trial court and affirmed his conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of R.C. 2967.271 (Reagan Tokes Law)	State: constitutional challenge was not raised below and is forfeited; court must not decide it first on appeal.	Alexander: statute unlawfully delegates authority to DRC to extend incarceration, violating due process under U.S. and Ohio Constitutions.	Court: Issue forfeited for failure to raise in trial court; assignment of error overruled; conviction/sentence affirmed.

State v. Awan, 22 Ohio St.3d 120 (1986) (constitutional challenge must generally be raised at the first opportunity—in criminal cases, in the trial court)
State v. Quarterman, 140 Ohio St.3d 464 (2014) (declined to decide an unraised constitutional issue on appeal)