State v. Bradford, 2012 Ohio 1058

Bradford, acting pro se, appeals five underlying criminal cases in which he pled to multiple counts in 2003–2004.
Following pleas, the court imposed consecutive sentences totaling 23 years, but journal entries only referenced postrelease control as part of the sentence.
Bradford filed postconviction relief motions in 2007 asserting improper imposition of postrelease control, which the court denied.
In 2008 Bradford moved for resentencing arguing improper advisement of postrelease control; the court denied within six days.
In 2011 Bradford moved to dismiss proceedings due to delay in sentencing, arguing lack of jurisdiction for resentencing.
The trial court initially denied dismissal but later granted resentencing and conducted a hearing in September 2011; Bradford appealed prior to resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether delay in sentencing deprived jurisdiction	Bradford	Bradford	No; court retained jurisdiction and could impose valid postrelease terms

State v. Najeeb, 2011-Ohio-6081 (8th Dist. Nos. 96689 and 96690 (2011)) (resentencing limited to postrelease-control portion)
State v. Fischer, 128 Ohio St.3d 92 (2010-Ohio-6238) (void postrelease-control; complete resentencing not required for postrelease-control issues)
State v. Bezak, 114 Ohio St.3d 94 (2007-Ohio-3250) (Bezak-Fischer framework for postrelease-control resentencing)
State v. Harris, 2011-Ohio-482 (8th Dist. No. 95010 (2011)) (delay in sentencing doctrine not fatal to jurisdiction)
State v. Singleton, 124 Ohio St.3d 973 (2009-Ohio-6434) (jurisdiction to impose postrelease-control sentences preserved where resentencing pending)
State v. Simpkins, 117 Ohio St.3d 420 (2008-Ohio-1197) (jurisdiction retained to complete postrelease-control terms)