State v. Rice, 2011 Ohio 1929

Rice was convicted in 2002 of five counts of rape and sentenced to five consecutive 10-to-life terms, classified as a sexual predator.
Rice sought postrelease control relief in 2010 by filing a motion to vacate void judgment, which the trial court denied.
Appellate review concerns whether failure to properly inform about postrelease control at sentencing renders the sentence void.
A journal entry stating only that postrelease control is part of the sentence may be insufficient if it omits the possibility of additional incarceration for violations.
The record lacked a transcript of the sentencing hearing, so the court presumed regularity but found merit in the journal-entry defect requiring remand.
The court ultimately remanded to correct the sentencing entry to reflect that Rice could face further incarceration if he violates postrelease control, without ordering de novo resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to inform about postrelease control at sentencing voids the sentence	Rice argues void sentence due to improper notice	Rice did not prove notice failure without transcript; presumed regularity	Partial merit; journal-entry defect requires remand for correction
Whether journal-entry omission on postrelease terms requires reversal	Rice asserts need to state possible further incarceration	Journal entry need not specify all contingencies if otherwise clear	Reversible error; remand to correct journal entry
Whether remand for correction is proper rather than de novo resentencing	Defective notice warrants resentencing	Fischer allows correction without full remand in limited cases	Remand for correction of entry; not de novo resentencing

Woods v. Telb, 89 Ohio St.3d 504 (2000) (postrelease control must be informed at sentencing)
State v. Fischer, 128 Ohio St.3d 92 (2010) (defect corrected without remand when appropriate; postrelease control mandate)
Bezak, 114 Ohio St.3d 94 (2007) (Bezak framework for postrelease control sentencing)