State v. Smith, 2012 Ohio 2728

May 2011 grand jury indicted Smith for robbery and trafficking cocaine; bill of particulars describes plan, meeting at BP Station, theft of cell phone and $20 after threatening the complainant.
Plea: Smith pleaded guilty to robbery; trafficking charge dismissed; trial court sentenced him to two years and notified postrelease control for three years.
Court advised that, after release, violation of postrelease control could lead to parole board-imposed prison term up to half the original sentence.
Smith timely appealed, arguing the sentence was contrary to law for lack of notification about consequences of committing a new felony while on postrelease control.
Court analyzed whether such specific notification is required and concluded it is not mandated by statute; the sentence was not void.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must court inform about new-felony consequences on PRC?	State asserts required notification includes potential prison term for violations.	Smith contends no statutory duty to warn about new-felony consequences.	No such required notification; sentence not void.

State v. Williams, 2010-Ohio-1879 (1st Dist. 2010) (statutory duty; failure to notify may render sentence void)
State v. Jordan, 104 Ohio St.3d 21 (2004-Ohio-6085) (postrelease control notification framework)
State v. Fischer, 2010-Ohio-6238 (2009-Ohio-6238) (specific postrelease control consequences not required to void entire sentence)
State v. Susany, 2008-Ohio-1543 (7th Dist. 2008) (absence of notification not fatal to sentence)
State v. Black, 2010-Ohio-2701 (7th Dist. 2010) (clarifies postrelease notice scope)