State v. Jackson, 2020 Ohio 4115

Edward Jackson was convicted in 1989 of multiple violent and sexual offenses and sentenced to an aggregate indefinite term (51–105 years); he remains incarcerated and has parole scheduled for 2022.
Ohio enacted Am.Sub.S.B. No. 231 ("Sierah's Law") creating a violent offender database requiring ten years of annual registration for qualifying offenders; some registration data is public.
Jackson was notified in prison that he is classified as a "violent offender" and moved for a de novo sentencing hearing, claiming the registration requirement is retroactive, an ex post facto law, and violates due process.
The trial court denied Jackson's motion as premature; the State argued the claim was not ripe and Jackson had not asserted the statutorily required rebuttal (that he was not the principal offender).
The Tenth District affirmed: it found the challenge not ripe and, in any event, de novo resentencing is not an available remedy for an unlawful post-sentence registration requirement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retroactive/ex post facto challenge to S.B. 231	Registration may be civil and not punitive; claim not ripe until release	Registrationretroactively modifies sentence; violates ex post facto and due process	Court declined to decide merits as claim not ripe; suggested statute resembles civil/administrative regime under precedent
Availability of de novo sentencing as remedy	State: de novo sentencing not appropriate relief	Jackson sought de novo resentencing to avoid registration duties	Denied: de novo sentencing unavailable; proper remedy would be reinstatement of original judicial orders if registration were unconstitutional
Trial-court jurisdiction/continuing jurisdiction under S.B. 231	Court: statutory rebuttal motion must assert not principal offender; otherwise no basis for continuing jurisdiction	Jackson filed for de novo hearing and declaratory relief, not the statutory rebuttal	Concurring opinion: trial court lacked jurisdiction because Jackson did not assert he was not the principal offender as required by R.C. 2903.42

Smith v. Doe, 538 U.S. 84 (2003) (held Alaska sex-offender registry nonpunitive for ex post facto analysis)
State v. Cook, 83 Ohio St.3d 404 (1998) (Ohio held sex-offender registration remedial, not ex post facto)
State v. Williams, 129 Ohio St.3d 344 (2011) (Ohio held S.B. 10's registration changes punitive and retroactive under state constitution)
State v. Bodyke, 126 Ohio St.3d 266 (2010) (remedy for unconstitutional post-sentence registration is reinstatement of prior judicial orders)
State v. Ferguson, 120 Ohio St.3d 7 (2008) (addressed changes to Ohio sex-offender registration statute)