State v. Halsey, 2015 Ohio 3405

William Halsey pled guilty to one count of sexual battery (2009) and was informed at sentencing he would be classified as a Tier III sex offender and required to register every 90 days for life.
Halsey signed a written explanation of registration duties at sentencing, but that form was not filed and is not in the record.
The October 29, 2009 sentencing entry imposed three years of community control but did not state Halsey was a Tier III sex offender; related probation-condition filings likewise omitted the classification.
Halsey completed community control; his case was terminated in February 2012, yet the sheriff continued enforcing Tier III registration duties.
In September 2014 Halsey moved to vacate the Tier III classification, arguing the omission in the journal entry violated R.C. 2929.19(B)(3) and that the court lacked jurisdiction to impose the classification after case termination. The trial court denied the motion.
On appeal the court considered whether there was anything to vacate given the absence of a journaled sentencing entry imposing the Tier III classification.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Halsey)	Held
Whether the Tier III classification is void because the sentencing entry failed to state the classification as required by R.C. 2929.19(B)(3)	The sentencing hearing provided proper notice and the omission in the entry can be corrected (nunc pro tunc or resentencing)	The omission renders the classification void; court lacked jurisdiction to impose it after case termination	Court held there was no classification journaled to vacate; denial of motion to vacate affirmed

State v. Kase, 187 Ohio App.3d 590 (7th Dist. 2010) (trial court's failure to include Tier III classification in sentencing entry rendered entry deficient and required resentencing)