State v. Johnson, 2020 Ohio 191

Ricky Johnson (aka Rodney Knuckles) was indicted for murder in 1981; a jury convicted him and he was originally sentenced to 15 years to life.
The 1982 appeal reversed and remanded for failure to instruct on self-defense; Johnson waived a jury for the 1983 retrial, was convicted, and was sentenced to "fifteen (15) years to life" (the sentencing entry omitted the word "indefinite").
Over the next decades Johnson filed multiple postconviction motions and appeals challenging assorted issues (jury waiver, jurisdiction, etc.), which were repeatedly denied or dismissed; an earlier appeal on a jury-waiver issue was dismissed as barred by res judicata.
In March 2019 Johnson filed a motion to vacate his sentence claiming the omission of the word "indefinite" rendered his 15-to-life sentence void and denied him minimum-time deductions/parole eligibility.
The trial court denied relief; on appeal the Eighth District held the omission did not make the sentence void, and because the sentence is not void res judicata bars Johnson’s claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the omission of the word "indefinite" renders a 15-years-to-life sentence void	The State: the phrase "15 years to life" is inherently indefinite and satisfies statutory sentencing requirements; omission of the word is inconsequential	Johnson: omission of the statutory term "indefinite" makes the sentence not authorized by law (void) and affects minimum deductions/parole	Court: Sentence is not void; "15 years to life" is an indefinite term and comported with R.C. 2929.02(B)
Whether res judicata is a bar to the claim	The State: res judicata bars claims that were or could have been raised unless the sentence is void	Johnson: claims an exception because a void sentence can be attacked at any time	Court: Because the sentence is not void, res judicata precludes relief

State v. Perry, 226 N.E.2d 104 (establishes res judicata bar for claims raised or that could have been raised)
State v. Fischer, 942 N.E.2d 332 (void-sentence exception to res judicata; void judgments may be attacked anytime)
State v. Bezak, 868 N.E.2d 961 (sentence void where court disregards statutory sentencing requirements)
State v. Jordan, 817 N.E.2d 864 (same principle: noncompliance with statutory sentencing can render sentence void)
State v. Beasley, 471 N.E.2d 774 (older Ohio precedent on void sentences for statutory noncompliance)
Colegrove v. Burns, 195 N.E.2d 811 (same principle regarding validity of sentences)
Yonkings v. Wilkinson, 714 N.E.2d 394 (statutory construction: words given their usual, normal meaning)
State v. Smith, 131 N.E.3d 321 (distinguishes aggravated-murder statutes that expressly set parole eligibility from murder statute that does not)