State v. Jones
2022 Ohio 1674
| Ohio Ct. App. | 2022Background
- Lee Jones, a convicted serial rapist already serving a 50-year aggregate term, pleaded guilty in 2016 to two additional rape counts and was sentenced in 2017 to consecutive 3-year terms; those convictions were affirmed on direct appeal in 2018.
- In 2019 the state filed supplemental discovery: a BCI "preliminary association" indicating a DNA hit to another individual on an unspecified sample; the timing and victim to whom the sample related were not identified.
- Jones moved to "vacate a void judgment and sentence," arguing the new DNA identification proved his innocence and that counsel coerced his plea; he expressly asked the court to treat the filing as a void-judgment challenge rather than a postconviction petition to avoid statutory time bars.
- The trial court denied Jones’s motion; he appealed the denial. The appellate court considered whether the trial court had jurisdiction to reopen or vacate the final convictions and whether Jones could withdraw his guilty plea post-sentencing.
- The court held Jones’s arguments did not show the convictions were "void" under the Harper/Henderson framework, that postconviction or DNA-testing statutes did not help a defendant who pleaded guilty, and that Crim.R. 32.1 withdrawal relief is not available after appellate affirmance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court could vacate convictions as "void" based on new DNA hit | State: convictions are not void; Harper/Henderson restricts "void" to jurisdictional defects | Jones: preliminary DNA match to another person proves actual innocence, making convictions void | Denied — no voidness shown; Harper/Henderson limits voidness to jurisdictional defects |
| Whether the motion should be treated as postconviction relief (R.C. 2953.21) | State: recast as postconviction, but petition would be untimely and unavailable to guilty pleas | Jones: expressly avoided invoking postconviction statute to escape timeliness bar | Jones cannot rely on untimely/successive postconviction relief; guilty pleas preclude showing an "error at trial" needed for relief |
| Availability of postconviction DNA-testing statutes (R.C. 2953.71–.84) | State: statutes exclude defendants who pleaded guilty from eligibility | Jones: DNA hit entitles him to relief | Denied — statutory scheme excludes guilty pleas from eligibility for postconviction DNA testing |
| Whether Crim.R. 32.1 postsentence plea withdrawal is available after appellate affirmance | State: trial court lost jurisdiction after convictions were affirmed; Crim.R.32.1 not available post-appeal | Jones: DNA evidence and coercion claims show manifest injustice warranting withdrawal | Denied — trial court lacks authority to vacate convictions after appellate affirmance; res judicata also bars these claims |
Key Cases Cited
- State v. Harper, 159 N.E.3d 248 (Ohio 2020) (clarifies limits on what constitutes a "void" sentence)
- State v. Henderson, 162 N.E.3d 776 (Ohio 2020) (reaffirms "void" is limited to jurisdictional defects)
- State v. Apanovitch, 121 N.E.3d 351 (Ohio 2018) (trial court lacked jurisdiction to consider postconviction or new-trial claims without a basis for continuing jurisdiction)
- State v. Schlee, 882 N.E.2d 431 (Ohio 2008) (courts may recast irregular motions into appropriate procedural categories)
- State v. Ketterer, 935 N.E.2d 9 (Ohio 2010) (trial court cannot vacate a judgment already affirmed on appeal)
- North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (guilty pleas may be entered while still protesting innocence)
- State ex rel. Cruzado v. Zaleski, 856 N.E.2d 263 (Ohio 2006) (continuing jurisdiction to correct only truly void judgments)
- State v. Simpkins, 884 N.E.2d 568 (Ohio 2008) (limits on trial court continuing jurisdiction after final judgment)
- State v. Jordan, 817 N.E.2d 864 (Ohio 2004) (same)
- State v. Stansell, 175 N.E.3d 547 (Ohio 2021) (pending Supreme Court consideration of trial-court power to correct certain sentencing errors)
- State v. Sterling, 864 N.E.2d 630 (Ohio 2007) (addressed and severed a statutory provision that had allowed guilty-plea defendants limited access to postconviction DNA testing)