State v. Robinson, 2020 Ohio 4470

In 2004 Robinson was convicted of rape (victim under 13), gross sexual imposition, and two counts of compelling prostitution; initially sentenced to 10 years and labeled a sexual predator.
On direct appeal this court vacated portions of the judgment and ordered resentencing, concluding Robinson should have received a life term for the rape; the Ohio Supreme Court declined further review.
In May 2006 the trial court resentenced Robinson to life with parole ineligibility for 15 years; Robinson filed multiple post‑sentencing motions (grand jury transcript, dismissal, sex‑offender readjudication) which were denied.
Between 2006 and 2019 Robinson filed 18 challenges to his convictions/sentence. In Sept. 2019 he filed a petition for postconviction relief and a motion to vacate as void, arguing the court lacked subject‑matter jurisdiction because no criminal complaint was filed against him.
The state opposed, asserting the petition was untimely/successive and that Robinson was charged by indictment; the trial court denied relief on Oct. 4, 2019. Robinson appealed and the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to consider petition for postconviction relief (timeliness / successive)	State: petition filed ~14 years after appeal; untimely and successive under R.C. 2953.21/.23 so trial court lacked jurisdiction	Robinson: petition was timely / merits his jurisdictional defect claim	Held: Petition untimely and successive; jurisdictional timeliness requirements not met; trial court lacked jurisdiction to entertain it
Whether absence of a criminal complaint (vs. indictment) deprived court of subject‑matter jurisdiction	State: charges were brought by indictment; lack of complaint does not defeat jurisdiction where indictment exists	Robinson: no complaint was filed; therefore trial court lacked subject‑matter jurisdiction and convictions are void	Held: Record shows municipal complaint and subsequent grand‑jury indictment; indictment suffices under Crim.R.7(A); no jurisdictional defect shown

State v. Gondor, 112 Ohio St.3d 377, 860 N.E.2d 77 (2006) (postconviction petitions are collateral attacks and review standards)
State v. Perry, 10 Ohio St.2d 175, 226 N.E.2d 104 (1967) (framework for postconviction relief)
State v. Apanovitch, 155 Ohio St.3d 358, 121 N.E.3d 351 (2018) (timeliness and successive‑petition rules are jurisdictional)
State v. Reynolds, 79 Ohio St.3d 158, 679 N.E.2d 1131 (1997) (motion to vacate void judgment may be treated as a postconviction petition)
State v. Robinson, 108 Ohio St.3d 1488, 843 N.E.2d 794 (2006) (Ohio Supreme Court declined further review of earlier appeal)