State v. Hall, 93 N.E.3d 35

In 2007 Hall pleaded guilty to multiple felonies and misdemeanors and was sentenced to an aggregate nine-year prison term; sentencing entry was journalized December 24, 2007.
The plea/sentencing agreement referenced a three-year post-release-control term, but the sentencing transcript and judgment entry stated a five-year mandatory post-release-control period.
Hall completed the imposed prison term March 30, 2016, but remained incarcerated on unrelated parole violations.
On August 29, 2016 Hall filed a pro se motion to vacate post-release control, arguing he was not properly advised of the mandatory nature of post-release control at plea/sentencing and that the notification in the journal entry was defective.
The trial court denied the motion, finding the court informed Hall at sentencing he "would be" subject to five years and the judgment entry stated the offender "shall be" subject to five years. Hall appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post-release-control notification was deficient such that the post-release-control portion of Hall's sentence is void and must be vacated	State: The sentencing court properly notified Hall at sentencing and journalized a mandatory five-year term; therefore post-release control is valid	Hall: He was not properly notified of the mandatory nature of post-release control (plea referenced "may" and he completed his term), so the post-release-control portion is void and cannot be corrected now	Court affirmed denial of Hall's motion: sentencing transcript and entry provided statutorily compliant notification (used mandatory language), so post-release-control portion is not void and Hall's claim fails

State v. Singleton, 124 Ohio St.3d 173 (holds R.C. 2929.191 cannot be applied retroactively)
State v. Fischer, 128 Ohio St.3d 92 (when court fails to impose statutorily mandated postrelease control pre-July 11, 2006, that portion is void and defendant is entitled to resentencing limited to postrelease control)
State v. Bloomer, 122 Ohio St.3d 200 (in absence of a proper sentencing entry imposing postrelease control, the parole board’s imposition cannot be enforced)
State v. Qualls, 131 Ohio St.3d 499 (trial court must give statutorily compliant postrelease-control notice at sentencing and incorporate it in the sentencing entry; omission may be corrected by R.C. 2929.191 or nunc pro tunc depending on circumstances)
State v. Palmer, 112 Ohio St.3d 457 (construing mandatory language and requirements for sentencing notifications)
State v. Payne, 114 Ohio St.3d 502 (distinguishes void versus voidable sentences and res judicata implications)