State v. Lusane, 2020 Ohio 737

In January 2000 Lusane was cited for traffic offenses and OVI; on May 12, 2000 he signed a written guilty plea to OVI and the plea form shows the judge accepted the plea.
The case file jacket and plea paperwork indicated "pled guilty" and bore the judge’s signature.
Separately on May 12, 2000 the trial court journalized a sentencing entry imposing fine, jail (with part suspended), and license suspension, but that entry did not state the fact of conviction or reference the specific charge.
In March 2019 Lusane moved to revise the judgment of conviction, arguing the sentencing entry failed to comply with Crim.R. 32(C) and therefore was not a final, appealable order; the trial court denied the motion.
This court granted a delayed appeal; the State conceded the entries did not meet Crim.R. 32(C)’s single-judgment requirement.
The appellate court reversed and remanded, directing the trial court to issue a single journal entry that sets forth both the fact of conviction and the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying Lusane’s motion to revise the sentencing/judgment entries that did not set forth both the fact of conviction and the sentence in a single journal entry	State conceded neither of the two separate entries complied with Crim.R. 32(C)’s single-judgment requirement	Lusane argued Crim.R. 32(C) and controlling precedent require a single final journal entry stating the fact of conviction and the sentence, so the denial was error	Reversed and remanded: trial court must issue one judgment entry containing both the fact of conviction and the sentence

State v. White, 130 N.E.3d 247 (Ohio 2019) (sets four-part rule for when a judgment of conviction is final: fact of conviction, sentence, judge’s signature, and clerk’s journal timestamp)
State v. Ginocchio, 526 N.E.2d 1366 (Ohio Ct. App. 1987) (addresses requirement that a judgment of conviction set forth the fact of conviction and the sentence)