State v. Jackson, 2012 Ohio 4280

Jackson pled guilty to rape and kidnapping in 2000, with charges amended to remove certain specifications; the offenses involved an 11-year-old household member.
Sentences imposed September 20, 2000: 9 years for rape and 8 years for kidnapping, consecutive for 17 years; no direct appeal filed.
Over the years, Jackson filed multiple Crim.R. 32.1 motions to withdraw pleas and related appeals, most dismissed for lack of record or untimeliness.
In 2011–2012, the trial court denied a motion to withdraw only the guilty plea to kidnapping; a postrelease control issue remained pending.
The appellate court affirmed, holding the postrelease-control portion is reviewable, res judicata bars others, and no manifest injustice was shown; remanded for execution of sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the postrelease-control voidness affects withdrawal of plea	Jackson	Jackson	Postrelease-control issue governs review; not all grounds tollable; denial affirmed
Whether the sentence voidness renders the Crim.R. 32.1 motion presentence	Jackson	Jackson	Motion not treated as presentence; res judicata applies to other issues
Whether allied-offense sentencing issues render the sentence void	Jackson	Jackson	Sentence not void; res judicata bars relief on allied-offense claims
Whether res judicata bars reconsideration after multiple attempts	State	Jackson	Res judicata precludes new challenges to issues that could have been raised earlier
Whether the trial court abused its discretion in denying Crim.R. 32.1 motion	State	Jackson	No abuse of discretion; denial affirmed

State v. Fischer, 128 Ohio St.3d 92 (2010) (void sentence postrelease-control ruling governs review; permissible narrow scope of appeal)
State v. Fountain, 2010-Ohio-1202 (8th Dist.) (Crim.R. 32.1; res judicata applies to issues not raised timely)
State v. Kelly, 2012-Ohio-2930 (8th Dist.) (allied-offense sentencing issues; voidable not void; res judicata)