State v. Holloman, 2014 Ohio 5763

In 2005 Martin Holloman was convicted of first-degree aggravated burglary and sentenced to six years' imprisonment plus post-release control (PRC).
At sentencing the court orally stated a five-year PRC term and warned PRC violations could yield up to one-half of the sentence in additional time; Holloman signed a written "Notice (Prison Imposed)" form detailing four possible PRC consequences but admits he did not read it.
The December 2005 journal entry contained the boilerplate "applicable periods of post-release control" language; a corrected entry was filed in 2009 with the same language.
Holloman previously appealed and lost (Holloman I) and later filed a first motion to vacate and terminate PRC that was denied and affirmed (Holloman II).
After a PRC violation Holloman served 150 days in custody and then filed a second motion to vacate a void sentence and terminate PRC, arguing the trial court failed to provide statutorily required oral and written warnings about PRC consequences.
The trial court denied the second motion; the Tenth District affirmed, finding the combination of oral advisement, the signed notice, and the sentencing entry satisfied the court’s statutory duties.

Issue	Holloman's Argument	State's Argument	Held
Whether the trial court failed to orally advise Holloman of PRC consequences as required by R.C. statutes	Trial court did not adequately describe the possible PRC sanctions (e.g., 9‑month sanction, cumulative one‑half term) so sentence is void	The court properly imposed PRC; relief should have been sought against APA if appropriate	Court held oral advisement (plus signed notice) satisfied statutory duty; overrules claim
Whether the sentencing entry failed to incorporate the required PRC term and consequences	Journal entry lacked explicit five‑year mandatory PRC term and the four enumerated consequences, rendering the sentence void	Entry plus other written/oral notifications constitute sufficient notice	Court held the entry, read with the oral advisement and signed notice, adequately notified Holloman and did not render sentence void

State v. Jordan, 104 Ohio St.3d 21 (Ohio 2004) (trial court must provide notice of postrelease control at sentencing)
State v. Singleton, 124 Ohio St.3d 173 (Ohio 2009) (reiterating statutory duty to notify of postrelease control at sentencing)
State v. Bloomer, 122 Ohio St.3d 200 (Ohio 2009) (when PRC is mandatory the court must notify offender of mandatory nature and length and incorporate notice into the entry)
State v. Fischer, 128 Ohio St.3d 92 (Ohio 2010) (a sentence that omits statutorily mandated PRC term is void)
State v. Simpkins, 117 Ohio St.3d 420 (Ohio 2008) (improper imposition of PRC may render that portion of the sentence void)
Nolan v. Nolan, 11 Ohio St.3d 1 (Ohio 1984) (law‑of‑the‑case doctrine explained)