State v. Taylor, 2019 Ohio 4485

In 2010 a jury (and bench on one count) convicted Gudonavon J. Taylor of multiple offenses including three murders and several non-murder felonies; the trial court merged some counts and imposed an aggregate term of 41 years to life.
Taylor pursued multiple appeals and collateral motions (Taylor I–IV and Taylor III rehearing) and those challenges were repeatedly rejected by this court.
Taylor filed a pro se motion for resentencing claiming the trial court improperly advised him about post-release control (PRC) by stating a single five-year PRC term instead of separately advising the PRC applicable to each offense.
The trial court denied the motion, finding it had properly notified Taylor, and the court of appeals affirmed.
The appeals court relied on R.C. 2967.28(F)(4)(c) and controlling precedent that when multiple PRC periods apply they run concurrently and the court need only notify the defendant of the longest applicable PRC term.
The court also held that even if PRC notification were erroneous, only the PRC portion (not the entire judgment) would be void and res judicata would still bar relitigation of other issues.

Issue	State's Argument	Taylor's Argument	Held
Whether the trial court’s PRC notification was defective such that the sentences are void	The court properly notified Taylor of the longest applicable PRC (five years); that suffices when multiple PRC periods apply	The court was required to notify Taylor of the distinct PRC term for each offense; failure voids the sentences	Court: Only the longest PRC need be stated; PRC portion is valid here and sentence is not void
Whether any PRC-notification error would deprive the trial court’s judgment of final appealable order status (thus stripping appellate jurisdiction)	Any PRC error would void only the PRC portion, not the entire sentencing judgment; judgment remains final and appealable	If PRC notice was defective then the sentencing judgment was not final, so Taylor I lacked jurisdiction and is void	Court: PRC error would not nullify the entire judgment; appellate jurisdiction was proper; Taylor I stands
Whether Taylor I must be vacated because the appellate court lacked jurisdiction	Same as above: prior appeal remains valid because judgment was final despite PRC issues	Taylor I is a nullity if the sentencing entry was not final due to PRC defects	Court: Taylor I is not void; prior appellate decisions remain valid

State v. Grimes, 85 N.E.3d 700 (Ohio 2017) (trial court must notify offender of PRC at sentencing and include notice in the judgment entry)
State v. Fischer, 942 N.E.2d 332 (Ohio 2010) (failure to impose required PRC renders that part of the sentence void)
State v. Holdcroft, 1 N.E.3d 382 (Ohio 2013) (clarifies that only the PRC portion is voidable and res judicata bars relitigation of other aspects of the conviction)
State v. Clark, 893 N.E.2d 462 (Ohio 2008) (unclassified felonies are not subject to PRC; parole eligibility governed separately)