State v. Mayfield, 2015 Ohio 5375

In 2007 Mayfield was indicted on a 31-count indictment for a multi-victim home invasion; later pleaded guilty to multiple counts and two specifications under a plea agreement.
Under the plea agreement several duplicate counts were to merge (four kidnappings into one, four aggravated robberies into one, two felonious assaults into one); remaining counts dismissed.
He was sentenced to an aggregate 23-year prison term on convictions including kidnapping, aggravated robbery, felonious assault, and having weapons while under disability, plus firearm and body-armor specifications.
Mayfield filed a delayed appeal in 2015 raising one assignment of error about allied-offense merger; the State conceded remand but the court evaluated under controlling precedent.
The appellate court found the sentencing entry and plea/sentencing transcript failed to properly impose and notify Mayfield of the mandatory five-year post-release control for first-degree felonies.
Result: the court affirmed convictions, vacated the post-release-control portion of the sentence, and remanded for a limited resentencing on post-release control; it overruled the allied-offense argument as forfeited.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by failing to analyze whether aggravated robbery and kidnapping were allied offenses subject to merger	Mayfield: Court should remand for the trial court to determine merger as required by precedent	State: (implicitly) no plain error shown because Mayfield did not raise merger below	Court: Issue forfeited for failure to raise below; under State v. Rogers defendant must show plain error and reasonable probability of merger; Mayfield made no such showing — assignment overruled
Whether post-release control was properly imposed and explained	Mayfield: (challenged the sentence on appeal)	State: did not contest that the sentencing entry and colloquy were defective	Court: Sentencing entry and plea hearing failed to impose/advise statutorily mandated five years of post-release control; that part of the sentence is void and vacated; remand for limited resentencing on post-release control

State v. Rogers, 143 Ohio St.3d 385 (2015) (defendant who fails to raise allied-offense issue below forfeits all but plain error; must show reasonable probability convictions are allied)
State v. Fischer, 128 Ohio St.3d 92 (2010) (failure to impose statutorily mandated post-release control renders that part of the sentence void)