State v. Elliott, 2014 Ohio 2062

In 2006, Elliott pled guilty to aggravated robbery and was sentenced to six years with five years of mandatory postrelease control (PRC).
The sentencing entry noted PRC but did not state the consequences of violating PRC.
After release, Elliott failed to report to his probation officer, leading to an escape charge under R.C. 2921.34(A)(3).
Elliott moved to dismiss the indictment and vacate the 2006 guilty plea; the court denied both motions.
The court sentenced Elliott to amended escape count and imposed one year of community control; three assignments of error challenged the denial and the PRC issue.
The issue framed by the court is whether PRC was validly imposed given the missing PRC consequences in the journal entry, and whether nunc pro tunc correction could save the PRC notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was PRC properly imposed where the journal entry failed to include consequences?	Elliott	Elliott	PRC notice in entry lacking; void imposition; indictment cannot stand
Can a nunc pro tunc correction fix the missing PRC notice after prison release?	State	Elliott	Nunc pro tunc correction barred after release; cannot validate void PRC
Is verbal notification sufficient to uphold a PRC imposition absent journal-entry wording?	State	Elliott	Verbal notice alone is insufficient; journal entry must reflect notice
Should the state be permitted to proceed with the escape indictment given void PRC?	State	Elliott	Indictment must be dismissed; postrelease-control cannot be imposed

State v. Jordan, 104 Ohio St.3d 21 (2004-Ohio-6085) (requires journal-entry notification of PRC consequences)
State v. Qualls, 131 Ohio St.3d 499 (2012-Ohio-1111) (nunc pro tunc corrections permitted when notice was given; not when notice was absent)
State v. Cvijetinovic, 2013-Ohio-5121 (8th Dist. Cuyahoga No. 99316) (clarifies timing and scope of PRC notice and corrections)