State v. Kidd, 2011 Ohio 6323

Kidd pled guilty in May 2003 to two counts of trafficking cocaine near a school, both second-degree felonies, with other charges dismissed.
The plea agreement provided five-year terms on each count to run consecutively and required forfeiture of $1,474 and a 1987 Camaro.
The trial court imposed the agreed sentence and notified Kidd that post-release control was optional up to a maximum of three years.
In February 2010 Kidd moved for resentencing, arguing his sentence was a nullity due to the optional PRC notation; the court denied without explanation.
This court reversed and remanded for resentencing according to law.
In October 2010 Kidd was resentenced with the same terms and was informed that post-release control is mandatory for three years since these are second-degree felonies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PRC must be separately imposed for each count	Kidd argues separate per-count PRC mandatory	State argues one notification suffices if terms identical	Single notification suffices; no per-count separation needed
Whether the docket entry affects validity of PRC imposition	Kidd contends the docket entry lacks per-count mandatory language	Clerk's docket is not controlling; judgment controls	Judgment entry controls; docket entry does not invalidate PRC

State v. Terry, 2010-Ohio-5391 (Ohio App. Dist.) (required notification and journalization of PRC length)
State v. Bloomer, 122 Ohio St.3d 200 (2009) (mandatory PRC length depends on rule for second-degree felonies)
State v. Martello, 97 Ohio St.3d 398 (2002) (PRC applicability varies by whether offense is sex or non-sex)
State v. Sulek, 2010-Ohio-3919 (Greene App.) (identical PRC terms may be notified once for multiple offenses)
State v. Scott, 2011-Ohio-5527 (Sandusky App.) (upholds single notification when counts share same PRC term)
State v. Deskins, 2011-Ohio-2605 (Lorain App.) (per-count vs. joint PRC notification)