State v. Armstrong, 2018 Ohio 191

In 1992 A.D. Armstrong was convicted after a bench trial of aggravated burglary and sentenced to 6–25 years; the conviction was affirmed on direct appeal.
Armstrong was later convicted in 2005 (Case No. 2004 CR 2162) of felonious assault with a firearm specification and received additional sentence time for the specification.
While incarcerated Armstrong filed numerous pro se motions in the 1992 case challenging the length and computation of his incarceration, including a 2016 motion asking the trial court to consider evidence that a gun specification had already been served.
The trial court reviewed the docket, found no gun specification attached to the 1992 conviction, and concluded it lacked jurisdiction to alter the Ohio Department of Rehabilitation and Correction’s (ODRC) sentence computations for Armstrong’s 2004 case.
The trial court overruled Armstrong’s motions (including a request for removal to county jail for a court date); Armstrong appealed, arguing among other things that the sentencing court failed to inform him about parole consequences.
The appellate court affirmed, holding Armstrong’s motion was filed in the wrong case and that he may not raise new, nonconstitutional issues on appeal that were not presented to the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by overruling Armstrong’s motion that his gun specification had already been served	The trial court correctly found no gun specification in the 1992 case and lacked jurisdiction to alter ODRC’s computation for the 2004 conviction	Armstrong contended he had already served the firearm specification and the court should consider evidence proving that	Affirmed: trial court properly overruled; the firearm specification was tied to a different case (2004 CR 2162), not the 1992 case, and the court lacked authority over ODRC sentence computations
Whether Armstrong may raise new sentencing/parole-advice claims on appeal that were not presented below	New, nonconstitutional issues not raised in the trial court are not properly before the appellate court	Armstrong argued the trial court failed to inform him at sentencing about Parole Board control and consequences for committing a felony on parole	Affirmed: appellate court refused to consider new issues first raised on appeal

State v. Anderson, 87 N.E.3d 1203 (2d Dist. 2017) (nonconstitutional issues raised for the first time on appeal are not properly before the reviewing court)
Shields v. Englewood, 876 N.E.2d 972 (2d Dist. 2007) (same principle: issues not raised below cannot be considered on appeal)