State v. Lewis, 110 N.E.3d 919

In 2009 Lyn Lewis pleaded no contest to sexual imposition (R.C. 2907.06) involving a 16‑year‑old and was classified as a Tier I sex offender.
At a post‑conviction proceeding labeled a “sexual predator hearing,” the court’s judge’s sheet and an entry indicated Lewis was adjudicated a Tier I offender, and Lewis signed a paper acknowledging the notice.
The court’s journal entry inadvertently included an outdated Megan’s Law form that checked “child‑victim predator” and stated lifetime registration and five‑day reporting, but the sheriff later gave Lewis the correct Adam Walsh Act notice (annual verification for 15 years, three‑day reporting).
In 2016 Lewis moved to vacate his classification and registration as void, arguing the court had actually classified him under Megan’s Law and the entry required lifetime registration and five‑day reporting.
The trial court granted the motion, found it lacked jurisdiction to correct the classification, and ordered Lewis removed from the registry; the state appealed.
The appellate court concluded the original classification was properly Tier I under the Adam Walsh Act, the court’s journal spoke for the court, and the correct remedy was to re‑notify Lewis, not vacate the classification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lewis was properly classified as a Tier I sex offender	State: Classification was proper under Adam Walsh because conviction fits Tier I	Lewis: Court entry and form show Megan’s Law child‑victim predator adjudication instead of Tier I	Held: Properly classified as Tier I; journal entry controls
Whether the incorrect court notice voided the classification	State: Incorrect lifetime term on form was clerical; sheriff provided correct notice	Lewis: Incorrect form required lifetime registration and five‑day reporting, rendering classification void	Held: Incorrect notice did not void classification; court must correct and provide proper notice
Whether the trial court had jurisdiction to correct the notification after sentence completion	State: Court retained authority to correct notification while registration duty still running	Lewis: Court lacked jurisdiction to "resentence" because criminal sentence was served	Held: Court had authority to correct the erroneous notice because reporting duty (penalty) remained unexpired
Whether registry removal was appropriate	State: Removal was improper because classification stands and should be corrected	Lewis: Registry removal was necessary due to void classification and erroneous form	Held: Removal order vacated; remand for proper notification and continuation of Tier I obligations

State v. Williams, 952 N.E.2d 1108 (Ohio 2011) (sex‑offender classification under Adam Walsh Act is automatic based on offense)
State v. Holdcroft, 1 N.E.3d 382 (Ohio 2013) (trial court may correct notification errors while registration duty remains)
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court speaks through its journal entries)