State v. Slagle, 2013 Ohio 230

Slagle pled guilty on August 6, 2010 to two drug possession counts and one receiving stolen property count; he was sentenced to six years and a $7,500 fine plus costs, with no appeal filed.
The August 9, 2010 sentencing entry imposed the mandatory fine; under RC 2925.11(E)(1)(a), the fine for a second-degree felony is at least half the maximum, here $7,500 of a $15,000 maximum.
On June 7, 2012, Slagle moved to vacate the imposition of costs, fines, and/or restitution; the trial court denied relief as to costs and restitution, but granted relief as to the $7,500 fine.
The State appealed, challenging the trial court’s authority to vacate a mandatory fine and arguing res judicata applied to the mandatory fine issue.
The trial court lacked authority to vacate its own valid judgment, and exceptions to vacating judgments (void sentence or clerical error) did not apply.
The appellate court reversed the trial court’s decision, holding the mandatory fine could not be vacated and remanding with costs to the appellee.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court could vacate the mandatory fine	State asserts court had no authority to reconsider its final judgment.	Slagle contends the court could vacate the fine under its post-judgment authority.	The trial court erred; mandatory fine cannot be vacated.

State v. Roberson, 2003-Ohio-4282 (5th Dist. 2003) (res judicata effect on trial court rulings and defenses raised at trial)
State v. Perry, 10 Ohio St.2d 175 (1967) (doctrine of res judicata and final judgments)
State ex rel. Cruzado v. Zaleski, 111 Ohio St.3d 353 (Ohio 2006) (no authority to vacate valid final judgments except void or clerical error)
State ex rel. Hansen v. Reed, 63 Ohio St.3d 597 (1992) (limits on court's jurisdiction to vacate final judgments)