State v. Andrews, 2011 Ohio 2462

Indictment (Jan 13, 2005) charged Andrews with two counts of aggravated robbery with firearm specifications.
Trial (Aug 2005) followed Andrews requesting self-representation; court allowed self-representation with shadow counsel.
Verdicts (Aug 2005) guilty on both counts and firearm specs; sentences: 10 years per aggravated robbery, 3 years per spec, consecutive for 26-year total.
Appeal filed; conviction affirmed in 2006 on direct appeal.
Bezak proceedings (2010) led to resentencing to correct postrelease-control error; Fischer decision (2010) clarified review scope and void sentences where postrelease control is misapplied.
Resentencing (Nov 17, 2010) again imposed 26-year aggregate and advised 5 years mandatory postrelease control; issue on appeal centered on postrelease-control validity and related standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the resentencing properly addressed postrelease control.	Andrews argues sentencing was void for postrelease-control issues and other impermissible factors.	(State) Fischer limits review to postrelease-control imposition; other issues barred by res judicata.	Resentencing issues beyond postrelease control are barred; sentence stands.

State v. Fischer, 128 Ohio St.3d 92 (2010-Ohio-6238) (postrelease-control imposition governs review of Bezak-type resentencing; voidity limited to postrelease-control portion)
State v. Bezak, 114 Ohio St.3d 94 (2007-Ohio-3250) (Bezak proceedings focus on proper postrelease-control imposition)