State v. Leegrand, 212 N.E.3d 869

Defendant Tyrone Leegrand II was convicted of murder (R.C. 2903.02(B)) with one- and three-year firearm specifications; acquitted of aggravated murder; additional convictions included felonious assault, carrying a concealed weapon, tampering with evidence, and weapons-under-disability.
The trial court merged counts and imposed an aggregate sentence of 18 years to life; the murder count's journal entry stated: “LIFE IN PRISON WITH ELIGIBILITY OF PAROLE AFTER 15 YEARS.”
The applicable statute, R.C. 2929.02(B)(1), prescribes “an indefinite term of fifteen years to life” for murder.
The Eighth District affirmed convictions but vacated the murder sentence and remanded for resentencing, concluding the entry’s wording sufficiently diverged from the statute.
The State appealed; the Ohio Supreme Court held that a sentencing entry need not verbatim track statutory phrasing so long as it conveys the same legal effect, and reversed the court of appeals’ vacation/remand as to the murder sentence while leaving other appellate directions intact.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Leegrand)	Held
Whether a sentencing entry must exactly replicate statutory wording for a murder term (R.C. 2929.02(B)(1)).	Exact statutory phrasing is not required; an entry that conveys the same meaning suffices.	The entry’s wording ("life in prison with eligibility of parole after 15 years") is meaningfully different from an "indefinite term of fifteen years to life."	No; exact statutory language is not required when the entry conveys the identical legal effect.
Whether the sentencing entry at issue complied with R.C. 2929.02(B)(1) or required vacation and resentencing.	The entry communicates the same minimum (15 years) and maximum (life) and is therefore consistent with the statute.	The phrasing converts an indefinite range into a definite life sentence with parole eligibility and thus does not comport with the statute.	The Supreme Court held the entry complied with R.C. 2929.02(B)(1); reversed the portion of the court of appeals vacating the murder sentence and remanding for resentencing.

Colegrove v. Burns, 175 Ohio St. 437 (1964) (a court may not substitute a sentence other than that provided by statute)
Schenley v. Kauth, 160 Ohio St. 109 (1953) (a court of record speaks only through its journal)
State v. J.M., 148 Ohio St.3d 113 (2016) (statutory construction centers on the plain language and legislative intent)
State v. Henderson, 161 Ohio St.3d 285 (2020) (reaffirming that journal entries, not oral pronouncements, define the sentence)
State v. Dowdy, 162 Ohio St.3d 153 (2020) (procedural context referenced by the Court in handling this appeal)
Metro. Securities Co. v. Warren State Bank, 117 Ohio St. 69 (1927) (different statutory wording is presumed to carry different meaning)