State v. Martin, 59 N.E.3d 641

In 1996 Carl M. Martin was convicted of aggravated vehicular assault and his driver’s license was "permanently revoked."
In 2014 Martin was stopped for expired tags; he admitted his driving privileges were under a lifetime suspension.
A Butler County grand jury indicted Martin for failure to display tags and driving under a specified lifetime suspension (R.C. 4510.18).
After a bench trial Martin was convicted of both offenses and sentenced to five years community control and a $25 fine.
Martin moved for judgment of acquittal under Crim.R. 29, arguing the state failed to prove a class one (lifetime) suspension because his 1996 revocation predated the current classification scheme.
The trial court denied the Crim.R. 29 motion; the court of appeals affirmed, concluding a former "permanent revocation" falls within the statutory class one (lifetime) suspension.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Martin was under a class one (lifetime) suspension	State: Martin’s 1996 permanent revocation is governed by the current classification and qualifies as a class one lifetime suspension	Martin: His 1996 revocation was not labeled a class one suspension; classification did not exist then, so the state cannot prove a class one suspension	Court: "Permanent revocation" is functionally equivalent to a class one suspension; evidence was sufficient
Whether treating the 1996 revocation as a class one suspension unlawfully modified sentence or applied the statute retroactively	State: Applying current classification does not change the original sentence and is not retroactive application of a criminal statute	Martin: Recharacterizing the 1996 revocation as class one effectively modifies his sentence and improperly applies new law	Court: No unlawful modification or impermissible retroactivity; offense (R.C. 4510.18) was enacted in 2007 and applied at time of conviction

State v. Carter, 72 Ohio St.3d 545 (provides standard for sufficiency review)
State v. Thompkins, 78 Ohio St.3d 380 (discussion of legal standard for reviewing criminal convictions)
State v. Jenks, 61 Ohio St.3d 259 (mandates view of evidence in light most favorable to prosecution for sufficiency)
State v. White, 29 Ohio St.3d 39 (distinguishes common meanings of "suspend" and "revoke")
State v. Rowe, 118 Ohio App.3d 121 (courts lack inherent authority to modify criminal statutes/sentences absent statutory authority)
State v. Redman, 163 Ohio App.3d 686 (former statute provided no authority to suspend, cancel, or modify sentence)