State v. Stults, 960 N.E.2d 1015

Stults was indicted in Seneca County on trafficking cocaine and permitting drug abuse, with a forfeiture specification seeking 20 items.
A suppression motion was filed and denied after a hearing in July 2010.
The state amended the forfeiture specification on August 30, 2010, reducing it from 20 to 16 items, which the trial court granted.
A jury found Stults guilty on both counts after a trial held August 30–September 1, 2010.
At a bifurcated hearing on forfeiture and sentencing, the court imposed concurrent seven-month sentences and entered a separate forfeiture order for the 16 items.
Stults appealed, but the appellate court dismissed sua sponte for lack of a final, appealable order because the forfeiture was not incorporated into the sentencing entry as required by Baker.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the appeal from a final, appealable order under Baker?	Stults contends the judgment is final and appealable.	Stults argues the separate forfeiture entry prevents finality.	Appeal dismissed for lack of final, appealable order.
Is a criminal-forfeiture order under R.C. 2981.04 part of the sentence for Crim.R. 32(C)?	Forfeiture should be included in the sentence, per Baker’s one-document rule.	Separate forfeiture entry suffices under certain interpretations.	Criminal-forfeiture order is part of the sentence and must be incorporated into the sentencing entry; separate forfeiture entry is not final under Baker.

State v. Baker, 119 Ohio St.3d 197 (Ohio Supreme Court 2008) (one-document rule for Crim.R. 32(C))
State v. Harris, 190 Ohio App.3d 417 (8th Dist. 2010) (forfeiture issues under Baker’s framework)
State v. Ketterer, 126 Ohio St.3d 448 (2010) (sentencing opinions in capital cases; exception to Baker)
State v. Postway, 2003-Ohio-2689 (12th Dist. 2003) (two journal entries; rejected as basis for final order under Baker)
State v. O'Black, 2010-Ohio-192 (3d Dist. 2010) (jurisdictional and finality considerations)