State v. Ford, 2012 Ohio 4384

In 1993 Ford was indicted on weapons under disability and felony possession of cocaine charges, and later pleaded guilty to two counts of aggravated trafficking.
The trial court sentenced Ford to three years in prison, which he served.
In 2012 Ford filed a relief-after-judgment motion challenging his 1993 convictions on multiple grounds, including indictment amendment, ineffective assistance, and grand jury issues.
The trial court denied Ford’s motion on its face.
Ford appeals, arguing the indictment amendment changed the offense identity and was not presented to the grand jury, among other matters.
The appellate court affirmed, holding Ford’s arguments were barred by res judicata and the judgment was not void.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the judgment void for lack of jurisdiction due to the indictment amendment and grand jury issue?	State argues amendment did not void jurisdiction; but Ford contends identity changed.	Ford asserts the amendment changed the offense and was not Grand Jury-presented.	Res judicata bars the claim; judgment affirmed.

State v. Golston, 71 Ohio St.3d 224 (1994) (conviction rights survive judgment; voidness not automatic)
State v. Blankenship, 111 Ohio App.3d 198 (1996) (void vs voidable judgments distinctions; appellate relief available)
Payne v. Jeffreys, 109 Ohio St.3d 239 (2006) (indictment validity and related errors should be raised on direct appeal)
State v. Bailey, 2011-Ohio-3246 (2011) (indictment amendment arguments reviewed on direct appeal)
In re J.N., 2008-Ohio-3435 (2008) (voidable vs void judgments; appellate procedure governs)
State v. Fischer, 128 Ohio St.3d 92 (2010) (res judicata applicability to post-judgment challenges)