State v. Lester, 130 Ohio St. 3d 303

2006: A jury convicted Lester of multiple crimes; he was sentenced to prison and advised about postrelease control.
Crim.R. 32(C) judgment entry stated the convictions but did not specify whether based on a guilty/no-contest plea or on a bench or jury trial.
On remand, the trial court resentenced Lester and corrected the postrelease-control portion, but again the judgment did not state how convictions were effected.
On April 5, 2010, the court sua sponte filed a nunc pro tunc entry adding that the conviction was by jury verdict, to reflect what occurred.
Appellant appealed the nunc pro tunc entry; the Third District dismissed for lack of jurisdiction, concluding the nunc pro tunc entry was issued only to correct a clerical omission and did not create a new final order or new appeal right.
The issues were further refined after the court acknowledged a conflict with State v. Lampkin and granted discretionary review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a nunc pro tunc correction creating a jury- verdict basis for conviction creates a new final order.	Lester; the nunc pro tunc entry retroactively creates a new final order.	State; correction merely reflects what occurred and does not create a new appeal right.	No new right of appeal is created by the nunc pro tunc entry.
Whether Crim.R. 32(C) requires the manner of conviction to be stated as a substantive element of the final order.	Lester; Baker’s language requires the manner of conviction to be included.	State; the manner of conviction is not a substantive requirement, only a form requirement.	Crim.R. 32(C) requires the fact of conviction and substantive elements, not the manner of conviction as a substantive requirement.
Whether the original judgment of conviction was a final, appealable order despite the lack of the manner-of-conviction language.	Lester; the judgment was final because it contained the four substantive Crim.R. 32(C) elements.	State; the absence of the manner-of-conviction language affected finality and required correction.	Original judgment was final and subject to appeal; lack of manner-of-conviction language did not defeat finality.

State v. Baker, 119 Ohio St.3d 197 (2008) (finality requires four elements; manner of conviction discussion clarified)
State v. Tripodo, 50 Ohio St.2d 124 (1977) (Crim.R. 32(C) aims to notify when a final judgment is entered; timing for appeal)
State ex rel. Alicea v. Krichbaum, 126 Ohio St.3d 194 (2010) (judgment entry complied with Crim.R. 32(C) when it showed a jury-trial conviction)
State v. Barr v. Sutula, 126 Ohio St.3d 193 (2010) ( Crim.R. 32(C) form vs. substance distinctions clarified through relatistic decisions)
State v. Culgan v. Medina Cty. Court of Common Pleas, 119 Ohio St.3d 535 (2008) (Crim.R. 32(C) compliance and finality considerations)