State v. Maser, 2016 Ohio 211

In 1998 Maser pled guilty to five counts of third-degree gross sexual imposition and was sentenced to five consecutive 3-year terms; the trial court designated him a sexual predator.
On appeal the consecutive-sentences issue was remanded for resentencing; in 1999 Maser was resentenced to the same consecutive terms and that resentencing was later affirmed on appeal.
Maser completed his prison term in November 2012 and, in November 2013, moved to vacate his post-release control on the ground the court did not properly impose/notify him of the mandatory post-release control term.
At the 1999 resentencing the court orally said Maser would have "up to a maximum five years" of post-release control; the written judgment referenced the court's oral and written notification of the "applicable periods" of post-release control and Maser signed a "Notice (Prison Imposed)" stating a five-year term.
The trial court denied Maser’s motion; on appeal the Tenth District affirmed, finding the totality of the circumstances (oral statements, written entry, signed notice) sufficiently informed Maser of the mandatory five-year post-release control term.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Maser’s post-release control term was void for failure to properly notify/impose PRC	State: sentencing satisfied statutory notice when read with the written entry and signed notice	Maser: oral wording (“up to” five years) and the journal entry were deficient, so PRC was not properly imposed	Court held PRC was properly imposed; sentence not void under the totality of the circumstances

None with official reporter citations available in the opinion (appellate decisions cited in the opinion were unpublished or cited by docket/Ohio citation). (The court relied on its own prior Tenth District precedent treating combined oral/written/notice documents as sufficient notice of post-release control.)