State v. Brown, 2012 Ohio 5484

Brown was convicted in 1997 of aggravated murder with firearm and death specifications, plus other felonies, and sentenced to life with parole eligibility after 30 years.
On remand after appellate reversal on principal-offender issue, the trial court resentenced Brown in 1999.
In 2009 Brown moved for resentencing, arguing improper post-release-control notification; a new sentencing hearing and entry followed in 2009.
In 2012 Brown appealed again, raising sufficiency and related sentencing issues; this Court held certain issues barred by res judicata and the August 2011 sentencing entry required no further appeal.
The trial court’s subsequent 2012 decision denying the pro se motion stood, and the Court of Appeals affirmed, with costs taxed to Brown.
Brown declined to appeal the August 15, 2011 sentencing entry, further reinforcing the res judicata bar.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for aggravated murder; relitigation barred by res judicata	Brown argues insufficiency of proof for aggravated murder	State argues issues barred; res judicata applies	Issue barred; res judicata precludes relitigation

State v. Perry, 10 Ohio St.2d 175 (Ohio 1967) (articulates res judicata doctrine in criminal prosecutions)
State v. Fischer, 128 Ohio St.3d 92 (2010) (post-release control framework; triggers review of sentencing)