State v. Earl, 2020 Ohio 1202

Abdul L. Earl was sentenced in two separate Lorain County cases: each court initially placed him on three years of community control for multiple-count convictions and later revoked community control and sentenced him to prison after violations.
Earl did not file timely direct appeals from the original community-control or subsequent prison sentences.
Nearly a year after his prison sentences, Earl filed two pro se motions to vacate void judgment in each case, arguing the trial courts imposed an improper "lump" community-control sentence covering multiple counts.
The trial courts denied both motions; Earl appealed those denials, and the appeals were consolidated in this Court of Appeals opinion.
Earl relied on the Ohio Supreme Court’s rejection of the federal sentencing-package doctrine (Saxon) to argue his sentences were void and therefore removable outside the direct-appeal window.
The Court of Appeals rejected Earl’s claim, concluding the sentences were not void and that res judicata bars his untimely attack on sentencing errors that should have been raised on direct appeal.

Issue	Plaintiff's Argument (Earl)	Defendant's Argument (State)	Held
Whether the trial courts’ imposition of a single "lump" three-year community-control sentence for multiple counts rendered the sentences void	Earl: A lump or package community-control sentence for multiple counts violates Ohio sentencing law (per Saxon) and is therefore void and subject to collateral attack	State: The sentences are not void; sentencing-package argument is a sentencing error that must be raised on direct appeal and is barred now by res judicata	Court: Denied — sentences not void; res judicata bars belated collateral attack

State v. Saxon, 109 Ohio St.3d 176 (2006) (rejects federal sentencing-package doctrine; Ohio courts must sentence each offense individually)
State v. Fischer, 128 Ohio St.3d 92 (2010) (res judicata does not bar review of truly void sentences; voidness limited to jurisdictional/authority defects)
State v. Payne, 114 Ohio St.3d 502 (2007) (distinguishes void from voidable sentences; jurisdictional defects render a sentence void)
State v. Williams, 148 Ohio St.3d 403 (2016) (identifies certain sentencing defects that render sentences void, including separate sentences for allied offenses)
State v. Beasley, 14 Ohio St.3d 74 (1984) (trial court must follow statutory sentencing requirements; failure can render attempted sentence void)
State v. Holdcroft, 137 Ohio St.3d 526 (2013) (errors in applying sentencing statutes generally must be raised on direct appeal)
State v. Simpkins, 117 Ohio St.3d 420 (2008) (sentencing errors are generally not jurisdictional and do not make a sentence void)