State v. Alford, 2011 Ohio 4811

In 2005, Alford pleaded guilty to failure to comply with an order or signal of a police officer and two counts of felonious assault with firearm and body armor specifications, receiving a 12-year prison term.
Alford appealed pro se; the first appeal was dismissed for lack of record, and a second pro se appeal was untimely dismissed.
After denial of a post-plea withdrawal motion, this court remanded for resentencing to correct postrelease control advisements under Singleton.
On remand, Alford, pro se, moved again to withdraw his plea; the trial court denied, and he was resentenced to 12 years with postrelease control imposed.
Alford challenged the denial of his presentence motion to withdraw his guilty pleas in a sole assignment of error.
The appellate court ultimately held that Special Prosecutors controls, affirmed the judgment, and discussed that Boswell and Fischer influence remand and void-sentence concepts regarding postrelease control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court lacked authority to consider Crim.R. 32.1 motion after appellate remand	Alford argues remand did not grant jurisdiction to revisit the plea.	Alford contends that postremand powers allow withdrawal motions under Crim.R. 32.1.	No error; remand limits scope; court affirmed the judgment.

State v. Pruitt, 2009-Ohio-859 (Ohio App. 8th Dist. 2009) (remand limitations on Crim.R. 32.1 motions after affirmance)
State v. Special Prosecutors v. Judges, 55 Ohio St.2d 94, 378 N.E.2d 162 (Ohio Supreme Court 1978) (trial court cannot vacate affirmed judgment; Crim.R. 32.1 limitations)
State v. Boswell, 121 Ohio St.3d 575, 906 N.E.2d 422 (Ohio 2009) (void sentence; postrelease control; presentence motion framework)
State v. Fischer, 128 Ohio St.3d 92, 942 N.E.2d 332 (Ohio 2010) (partial voidness of sentence; res judicata limited to other merits)