State v. Savage, 2012 Ohio 2276

Savage pleaded guilty to fifth-degree theft as part of a plea agreement.
The trial court sentenced Savage to five years of community control and ordered $25,000 restitution jointly with co-defendants.
The sentencing entry also required Savage to enter the SEPTA program at a correctional facility.
Two sentencing-related entries followed: July 21, 2010 and September 9, 2010, addressing SEPTA and employment status.
Savage appealed, but the court dismissed for lack of jurisdiction, finding no final appealable order existed.
The court concluded it cannot be created by combining multiple entries, and thus jurisdiction was lacking.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is a final appealable order	State argues the July 21 and Sept. 9 entries leave issues unresolved, so no final order exists.	Savage challenged his restitution and other trial-counsel issues on appeal.	No final appealable order exists; appeal dismissed for lack of jurisdiction.
Whether the SEPTA commitment and related entries create finality when considered together	State notes the July 21 entry contemplates further action on SEPTA commitment.	Savage preserved other issues but relief hinges on finality, not merits.	Cannot create final appealable order by combining separate entries; jurisdiction remains lacking.

State v. Baker, 119 Ohio St.3d 197 (2008) (only one document can constitute a final appealable order for non-capital offenses)
State v. Darget, 2010-Ohio-3541 (4th Dist.) (dismissal for lack of final appealable order)
Eddie v. Saunders, 2008-Ohio-4755 (4th Dist.) (jurisdictional sua sponte consideration for finality)
Bell v. Horton, 142 Ohio App.3d 694 (4th Dist.2001) (finality analysis in appealability)
State v. Threatt, 2006-Ohio-905 (Ohio St.) (unresolved issues render nonfinal order)
State v. Ketterer, 2010-Ohio-3831 (Court of Appeals) (distinguishing Baker in certain contexts; final order framework)