State v. Campbell, 2013 Ohio 1569

Campbell was convicted of rape in 2002 and classified as a sexually oriented offender under Megan's Law, with ten-year registration and 20-day notice requirements for address changes.
Senate Bill 10 (2007) implemented more stringent classification, registration, and community-notification provisions for sex offenders.
In 2011 Campbell was indicted for failing to notify the sheriff of an address change, pled guilty to failing to provide notice (second-degree felony), and was sentenced in 2011.
Campbell moved to withdraw his guilty plea and later moved to dismiss the indictment, arguing retroactive application of SB 10 violated law and that the indictment was facially invalid.
The Ohio Supreme Court later clarified restrictions on applying SB 10 to pre-enactment offenders in Brunning, Bodyke, and related decisions, affecting Campbell’s case.
The appellate court ultimately held that SB 10 cannot be retroactively applied to Campbell; the penalty must be determined under the pre-SB10 framework, resulting in reclassification to a third-degree felony and remand for sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether applying SB 10 retroactively to Campbell violates the separation-of-powers doctrine	Campbell	Campbell	Indictment not dismissed on retroactivity grounds; retroactivity issue resolved as to penalties
Whether Campbell's penalty should be governed by pre-SB10 law or SB 10 provisions	State	Campbell	Penalty must be under pre-SB10 version (third-degree felony); remand to adjust conviction and sentence accordingly

State v. Bodyke, 126 Ohio St.3d 266 (Ohio 2010) (separation-of-powers; cannot reopen final Megan's Law judgments)
State v. Gingell, 128 Ohio St.3d 444 (Ohio 2011) (retroactivity limits on SB 10; preexisting Megan's Law classifications)
State v. Williams, 129 Ohio St.3d 344 (Ohio 2011) (retroactive constitutionality of SB 10; new burdens on preexisting offenses)
State v. Palmer, 131 Ohio St.3d 278 (Ohio 2012) (SB 10 cannot be applied retroactively to offenders not subject to SB 10)
State v. Brunning, 134 Ohio St.3d 438 (Ohio 2012) (Bodyke does not require vacating convictions under Megan's Law when SB 10 applies; guidance on notices)
State v. Howard, 134 Ohio St.3d 467 (Ohio 2012) (pre-SB10 penalty framework governs offenses arising under Megan's Law)
State v. Ferguson, 120 Ohio St.3d 7 (Ohio 2008) (constitutional validity of Megan's Law provisions)
State v. Cook, 83 Ohio St.3d 404 (Ohio 1998) (Megan's Law notice requirements and repository of notice obligations)