State v. Brown, 2012 Ohio 2793

Brown was convicted on March 9, 2006; judgment of conviction and sentence issued though manner of conviction not stated.
December 9, 2005 motion to dismiss on speedy-trial grounds denied; case proceeded to trial and was affirmed on direct and postconviction appeals.
August 1, 2011 motion for reconsideration sought reconsideration of the 2005 denial; trial court misidentified the motion in its ruling.
October 26, 2011 ruling denied reconsideration, held final judgment existed, and relied on res judicata to bar further speedy-trial argument.
Court of Appeals concluded the trial court addressed the wrong motion but found no reversible error because no prejudice occurred after final judgment and due process was not violated.
As of April 10, 2012, this court maintained jurisdiction notwithstanding the nullity of a motion for reconsideration of a final judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reconsideration of a prior speedy-trial ruling was proper.	Brown argues the court reconsidered the wrong motion, violating due process.	State contends the court properly addressed the speedy-trial issue and final judgment controls.	No reversible error; final judgment bars reconsideration.

State v. Lester, 130 Ohio St.3d 303 (2011-Ohio-5204) (final judgment valid despite lack of manner of conviction)
State v. Lucas, 2004-Ohio-4929 (2d Dist. Montgomery No. 20052) (reconsideration of final judgment is a nullity)
State v. Brown, 2007-Ohio-2098 (2d Dist. Montgomery No. 21540) (affirmed speedy-trial denial on direct appeal)