State v. Hayes, 2014 Ohio 1263

Anthony Hayes pleaded guilty in 2007 to multiple offenses arising from two separate 2006 armed robberies: counts included aggravated robbery, robbery, kidnapping, and having weapons while under a disability.
Hayes previously litigated direct appeals and multiple postconviction motions between 2007 and 2012 without success.
In 2012 Hayes filed three motions in the common pleas court seeking to set aside or vacate his sentences and to correct void judgments, asserting ineffective assistance of counsel in plea negotiations and that the trial court failed to apply R.C. 2941.25 protections for allied offenses.
Hayes’s motions did not cite a statutory or rule basis; the trial court dismissed them.
On appeal the First District affirmed, holding the postconviction statutes (R.C. 2953.21 et seq.) provided the exclusive collateral remedy and Hayes’s filings did not satisfy the statutes’ timeliness or jurisdictional requirements; and that neither the ineffective-assistance claim nor the allied-offenses claim, even if proven, would render convictions void.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hayes’s motions were properly treated as postconviction petitions subject to R.C. 2953.21 et seq.	Hayes sought relief from sentences/pleas and challenged counsel; he argued the court could correct sentence defects.	Trial court (State) argued the postconviction statutes are the exclusive collateral remedy and Hayes did not invoke them or meet their requirements.	Court: Motions were reviewable under postconviction statutes; Hayes did not satisfy time/jurisdictional requirements, so court lacked jurisdiction to hear them on the merits.
Whether the claims alleged rendered the judgments void (allowing review at any time)	Hayes contended the sentence for allied offenses and plea-counsel failures made the judgments void and thus reviewable outside R.C. 2953.21.	State argued neither ineffective assistance during plea nor allied-offense sentencing errors automatically void convictions.	Court: Neither claim, even if true, would render convictions void; only void-judgment doctrine (e.g., Cruzado) allows unlimited review, but it did not apply here.

State v. Hayes, 120 Ohio St.3d 1489 (2009-Ohio-278) (Ohio Supreme Court entry concerning the earlier appeal)
State v. Schlee, 117 Ohio St.3d 153 (2008-Ohio-545) (postconviction statutes provide the exclusive collateral remedy)
State ex rel. Cruzado v. Zaleski, 111 Ohio St.3d 353 (2006-Ohio-5795) (court always has jurisdiction to correct a void judgment)