State v. Christie, 2011 Ohio 520

Christie pled guilty to attempted murder with a firearm specification, two kidnapping counts, and aggravated burglary; total 25-year sentence.
1998 incident: Christie entered sister-in-law’s home via window with a ladder, took wife at gunpoint, shot her, and shot himself; both survived with disfiguring injuries.
Competency evaluations in 1999 found Christie competent to stand trial; NGRI finding unsupported by evidence.
Plea agreement dismissed some charges; March 1999 sentencing imposed multiple consecutive terms totaling 25 years, with seven years for aggravated burglary running concurrently.
2009–2010 post-release control issues and Bezak/Fischer framework prompted resentencing and appellate challenges, focusing on validity of sentence and withdrawal of plea.
The court ultimately held that only the portion of the sentence relating to the improper imposition of postrelease control was void; the remainder remained valid; motion to withdraw plea denied after applying manifest injustice standard under post-sentencing context.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Postrelease control: entire sentence void?	Christie argues Bezak voids entire sentence.	State argues only offending portion void per Fischer.	Only offending portion void; remainder valid.
Motion to withdraw plea: pre- vs post-sentence	Motion should be liberally granted as pre-sentence.	Bezak/Fischer framework treats as post-sentence with manifest-injustice standard.	Motion treated as post-sentence; denied for lack of manifest injustice.
Counts II–IV: merger/ally Offenses	Counts involve allied offenses that should merge.	Offenses not allied; Johnson framework applied to determine merger.	Counts not required to merge; no error in sentencing.
Plea knowing, voluntary, intelligent	Plea was not knowingly, voluntarily entered due to multiple counts.	Record shows defendant understood charges; no prejudice.	Plea was knowingly, voluntarily entered.
Competency hearing requirement	Trial court failed to hold separate competence hearing.	Evaluations showed competency; hearing not required given findings.	Harmless error; no voidable plea.

State v. Boswell, 121 Ohio St.3d 575 (2009-Ohio-1577) (postrelease control issues can render only offending portion void; not entire sentence)
State v. Bezak, 114 Ohio St.3d 94 (2007-Ohio-3250) (Bezak procedure for correcting postsentencing error; scope limited to postrelease control issue)
State v. Xie, 62 Ohio St.3d 521 (1992) (liberal standard for pre-sentence withdrawal of guilty plea; post-sentence requires manifest injustice)
State v. Smith, 49 Ohio St.2d 261 (1977) (post-sentence withdrawal requires manifest injustice; extraordinary remedy)
State v. Fischer, Slip Opinion No. 2010-Ohio-6238 (2010) (scope of appeal limited to resentencing on postrelease control; res judicata applies to other merits)