State v. Ratliff, 2021 Ohio 1187

In 1996 Ratliff was convicted of aggravated murder and the trial court sentenced him to "a term of life imprisonment" without explicit parole-eligibility language.
Ratliff appealed his conviction (not his sentence); this court affirmed in 1997 and the direct-appeal window closed.
In November 2019 Ratliff filed a postconviction motion to vacate his sentence as void for omitting parole-eligibility; the trial court scheduled and held a resentencing hearing in January 2020.
At resentencing the court imposed "life" with the added language "Parole Eligibility After Serving 20 Years." Ratliff had already received multiple parole hearings despite the omission.
While the appeal was pending, the Ohio Supreme Court issued State v. Harper and State v. Henderson, holding that sentencing errors are voidable (not void) when the sentencing court had jurisdiction.
The appellate court held the trial court lacked jurisdiction to resentence in 2020, vacated the 2020 resentencing, and remanded with instructions to reimpose the original 1996 sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a sentencing error that omitted parole language renders the sentence void or voidable	Sentence is voidable under Harper/Henderson when sentencing court had jurisdiction	Omitted parole-eligibility made the 1996 sentence void and unenforceable	Held: Voidable, not void; such errors must be raised on direct appeal
Whether the court had jurisdiction to resentence Ratliff in 2020 after the direct-appeal period closed	The 1996 judgment remained the operative sentence; court lacked authority to resentence via postconviction motion	Ratliff argued the original sentence never validly occurred, so resentencing or release was required	Held: Trial court lacked jurisdiction to resentence; 2020 resentencing vacated and remanded to reimpose 1996 sentence
Appropriate remedy when a sentencing error is discovered long after sentencing and direct appeal window	State noted DRC treated the sentence as life with parole eligibility and emphasized finality under Harper/Henderson	Ratliff sought vacatur and release or resentencing correcting the error	Held: Court expressed concern about fairness but followed Harper/Henderson; remedy was to vacate the unauthorized 2020 resentencing and direct reimposition of the original sentence

State v. Harper, 159 N.E.3d 248 (Ohio 2020) (sentences based on error are voidable, not void)
State v. Henderson, 162 N.E.3d 776 (Ohio 2020) (same rule: voidable sentencing errors must be raised on direct appeal)
Smith v. Sheldon, 131 N.E.3d 1 (Ohio 2019) (common pleas courts have subject-matter jurisdiction over felony cases)