State v. Minite, 2011 Ohio 3585

Defendant Minite pled guilty to five counts of receiving stolen property and one count of theft as part of a plea deal; remaining counts were dismissed.
Trial court sentenced to eight months on each count, consecutive for a four-year term; journal entry claimed three years postrelease control.
The sentencing entry stated explicit postrelease-control language; the court failed to provide required notices at sentencing.
Appeal raised that postrelease-control imposition was improper and consecutive sentences lacked statutorily required findings.
Court held: (1) remand for proper imposition of postrelease control; (2) consecutive-sentence findings not required by Foster after Ice; (3) various pro se supplemental arguments addressed with limited disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether postrelease control was properly imposed.	Minite argues improper imposition voids sentence.	State contends entry corrected error and error harmless.	Remand for proper imposition under 2929.191.
Whether consecutive sentences complied with 2929.14(E)(4) findings.	Minite contends missing findings required resentencing.	State argues no constitutional requirement for such findings post-Ice.	Overruled; no reversal on this basis; Foster not undermined.

State v. Singleton, 124 Ohio St.3d 173 (Ohio 2009) (remedy under 2929.191 for improper postrelease control notice)
State v. Bloomer, 122 Ohio St.3d 200 (Ohio 2009) (requirement to notify about postrelease-control consequences)
State v. Kelley, 2011-Ohio-88 (Ohio 2011) (notice requirements for postrelease control)
State v. Nicholson, 2011-Ohio-14 (Ohio 2011) (postrelease-control handling on appeal)
State v. Hodge, 128 Ohio St.3d 1 (Ohio 2010) (Ice does not require reimposition of Foster findings)
Foster v. Ohio, 109 Ohio St.3d 1 (Ohio 2006) (precedent on consecutive-sentencing findings)
Ice v. Oregon, 555 U.S. 160 (U.S. 2009) (federal precedent on consecutive-sentencing findings)