State v. Qunnie, 2014 Ohio 1435

Qunnie, convicted in 1997 of aggravated murder, aggravated burglary, and aggravated robbery with firearm specifications; sentences consecutive and concurrent as specified.
Crimes occurred on May 30, 1996, before the effective SB 2 date (July 1, 1996).
Qunnie appealed his conviction in 1997; this court affirmed, and the Ohio Supreme Court dismissed further review; reopening denied.
In 2013, Qunnie moved for de novo sentencing in the trial court; motion denied and appealed.
The appellate court analyzes postrelease control, statutorily mandated findings, jail-time credit, mandatory firearm-term, and firearm-spec sentencing entries.
The court ultimately affirms, holding that most challenges are barred by res judicata and that postrelease control provisions do not apply to pre-SB 2 crimes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
De novo sentencing due process	Qunnie argues denial violated Billiter-based procedures.	Qunnie contends trial court erred in not applying amendments.	Overruled; no error found on the issue.
Statutorily mandated findings under SB 2	Qunnie asserts lack of required findings on record.	Findings were not required for pre-SB 2 crimes.	Barred by res judicata; provisions do not apply to pre-SB 2 crimes.
Jail-time credit	Sentence lacked proper jail-time credit.	Credit issue was not raised on direct appeal.	Barred by res judicata.
Mandatory prison term for firearm specification	Court imposed improper mandatory term for firearm spec.	Challenge was not timely raised on direct appeal.	Barred by res judicata.
Journal entry—two firearm specifications	Journal entry failed to reflect sentences for multiple firearm specs.	Issue could have been raised on direct appeal.	Barred by res judicata.

State v. Rush, 83 Ohio St.3d 53 (1998) (SB 2 applicability limited to crimes committed on/after July 1, 1996; postrelease control not applicable to pre-SB 2 sentences)