State v. Hazlett, 191 Ohio App. 3d 105

Hazlett challenged his SB 10 reclassification as a severed AWA provision.
Hazlett was convicted of rape in 1980; no prior judicial sex-offender classification existed; classification arose by operation of law.
SB 10 altered Megan's Law into a three-tier system; reclassification caused life reporting duties.
Hazlett filed petition to contest reclassification on Jan 30, 2008, and sought stay of community notification.
Trial court denied petition Oct 2009 and lifted the stay; this appeal followed.
Supreme Court of Ohio later severed R.C. 2950.031 and 2950.032, removing AG reclassification authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the reclassification unconstitutional under separation of powers?	Bodyke controls; severance required.	Legislature intact; reclassification valid.	First assignment sustained; severance invalidates reclassification.
Does SB 10 apply to those not previously registered under prior law?	Application improper to those not previously registered.	SB 10 retroactively applies.	Moot after ruling on first issue; severance governs.
Does SB 10 violate ex post facto for pre-enactment offenses but post-enactment sentences?	Violates US and Ohio ex post facto clauses.	No violation under precept of SB 10.	Moot; severance dictates outcome.
Does retroactive SB 10 enforcement violate Ohio retroactivity clause?	Constitutional retroactivity ban applicable.	No retroactivity violation.	Moot; severance controls.
Does SB 10 retroactivity infringe Double Jeopardy protections?	Violated by retroactive reclassification.	No double jeopardy issue.	Moot; severance resolves the dispute.

State v. Bodyke, 126 Ohio St.3d 266 (2010-Ohio-2424) (severed AWA reclassification provisions as unconstitutional; reinstated prior classifications)
Chojnacki v. Cordray, 126 Ohio St.3d 321 (2010-Ohio-3212) (affirmed severance; dismissed appeal arising under severed provisions)