State v. Ali, 2012 Ohio 2510

Ali was convicted in 2006 on multiple rape offenses with concurrent life terms to be served after four years for unlawful sexual conduct with a minor, with a mandatory five-year postrelease control (PRC).
The trial court's 2006 sentencing entry failed to include PRC notifications as required by statute.
Ali and the state filed motions to correct the void judgment recognizing the deficiency.
On December 17, 2010, the trial court conducted a de novo resentencing and issued a new entry that included PRC notification reincorporating the original prison terms.
Ali challenged the sufficiency of the PRC notice, arguing the absence of the word 'mandatory' and the lack of oral notification of appellate rights.
The court held the PRC notice satisfied statutory requirements, did not require the word 'mandatory,' and noted the transcript was missing for review of the oral-notification issue, affirming the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the PRC notification adequate to convey mandatory PRC terms?	Ali argues the word 'mandatory' was omitted.	State contends the notification, through language used, conveys the mandatory nature.	Notification sufficient; word 'mandatory' not required.
Does omitting the word 'mandatory' render the sentence void?	Ali argues voidness due to missing term.	State asserts proper statutory notification despite omission.	No voiding; proper notice conveyed mandatory nature.
Can the oral-notification of PRC terms and appellate rights be reviewed without the transcript?	Ali seeks review of oral notices.	Record lacks transcript; regularity presumed.	Absent transcript, cannot review; decision affirmed.

State v. Bloomer, 122 Ohio St.3d 200 (2009) (mandatory nature and length of PRC must be conveyed, not by magic word)
State v. Holloman, 2011-Ohio-6138 (2011) (word 'mandatory' not required if terms conveyed)
State v. Williams, 2011-Ohio-3267 (2011) (transcript requirement for appellate review; regularity presumed without transcript)