State v. Ford, 2012 Ohio 5050

Ford pleaded guilty in 1996 to felonious assault with a firearm specification and was sentenced to 3 years (firearm spec) plus 10–25 years, to be served consecutively but concurrent with a federal sentence.
The trial court ordered Ford conveyed to a state facility to commence intake and then returned to federal authorities to begin serving the federal sentence.
Federal authorities would not take custody while Ford remained in state prison, prompting a 1999 motion to withdraw the guilty plea due to non-beginning of the federal sentence.
In 1999 the court vacated Ford’s sentence, granted bond and released him into federal custody, and ordered re-sentencing on July 1, 1999.
On February 16, 2000, the court, on its own motion, reinstated Ford’s original sentence; in 2012 Ford sought relief from judgment, which the court denied.
The appellate court held the reinstatement order void but determined the original December 23, 1996 sentencing entry remained a valid final judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Relief from judgment is barred by res judicata?	Ford contends the motion was timely and not barred.	Court treated claims as res judicata and untimely post-conviction relief.	Denied; res judicata did not invalidate the underlying judgment, but the reinstatement order was void.
Whether the reinstatement of sentence was void and affected Ford's current confinement?	Reinstatement after vacating the sentence deprived court of jurisdiction; reinstatement void.	Reinstatement was proper recapture of authority; however, the initial reinstatement might be void.	Reinstatement order void; original sentencing entry remains valid.
Does the appellate court lack subject matter jurisdiction because the sentencing entry is void?	Void entry strips appellate court of jurisdiction.	Appellate authority remains to address void judgments.	Appellate court possessed jurisdiction; assignment overruled.

State ex rel. Hansen v. Reed, 63 Ohio St.3d 597 (1992) (trial courts cannot reconsider valid final judgments)
State v. Carlisle, 131 Ohio St.3d 127 (2011) (final judgment and authority to reconsider)
State v. Baker, 119 Ohio St.3d 197 (2008) (final judgment components; journal entry requirements)
State v. Barclay, 2011-Ohio-4770 (9th Dist.) (de novo review standard applies to some questions of law)
State v. Bedford, 184 Ohio App.3d 588 (2009-Ohio-3972) (court may vacate a void judgment as a nullity)
Van DeRyt v. Van DeRyt, 6 Ohio St.2d 31 (1966) (void judgments and inherent power to address them)
Ohio Bell Tel. Co. v. Pub. Utils. Comm., 64 Ohio St.3d 145 (1992) (de novo review principle and standard of review for questions of law)