State v. Lockhart, 2021 Ohio 2418

In 2006 Lockhart was convicted of three counts of rape and three counts of gross sexual imposition for assaults on a 9‑year‑old and sentenced to an aggregate term of life imprisonment.
He appealed; this court affirmed the convictions and sentence and Lockhart did not challenge the life sentence on direct appeal.
Over the years Lockhart filed multiple collateral challenges (federal habeas, state mandamus, state habeas, motions to correct/clarify sentence and for resentencing); those efforts were denied or dismissed.
In 2020 Lockhart moved to "clarify his sentence," asserting the rape and GSI terms were ordered concurrent, which—he argued—should make the rape indefinite term 4 years to life rather than 10 years to life.
The trial court overruled the motion on June 2, 2020; the court of appeals affirmed, holding the claim barred by res judicata and that the motion could not compel the Bureau of Sentence Computation to recalculate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred in refusing to "clarify" Lockhart's sentence and notify the Bureau of Sentence Computation to recalculate so the rape term is 4‑to‑life rather than 10‑to‑life	State: Claim is barred by res judicata; prior appellate/collateral litigation already addressed sentencing; motion cannot compel Bureau action	Lockhart: Sentences were ordered concurrent; court/Bureau miscalculated leading to a longer indefinite rape term	Court affirmed: claim barred by res judicata; motion insufficient to compel the Bureau; judgment affirmed

State v. Cole, 2 Ohio St.3d 112 (Ohio 1982) (res judicata bars raising claims that were or could have been raised on direct appeal)
State ex rel. Lockhart v. Whitney, 130 Ohio St.3d 95 (Ohio 2011) (denial of writ of mandamus challenging postconviction process)
State ex rel. Lockhart v. Sheldon, 146 Ohio St.3d 468 (Ohio 2016) (state habeas relief denied)