State v. Thompson, 2021 Ohio 642

Darius R. Thompson pled guilty in 2011 to multiple offenses and was sentenced on February 16, 2012 to two years of community control, beginning March 5, 2012.
The trial court issued a March 13, 2014 entry releasing Thompson “wholly, fully, and completely” from community control and restoring his rights.
The sentencing entries never notified Thompson of any sex-offender registration obligations under R.C. 2950.01 et seq.
After Thompson was later incarcerated on separate charges and released in 2019, court personnel discovered the registration omission.
In May 2020 the trial court sua sponte held a limited resentencing hearing more than six years after Thompson’s community control ended and ordered him to register as a Tier II sex offender.
Thompson appealed, arguing the trial court lacked jurisdiction to impose registration requirements after his sentence had been completed and terminated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court may resentence a defendant and impose sex-offender registration requirements after the defendant’s sentence (community control) has been fully served and terminated	State: The court lacked jurisdiction to change sentence after completion (State conceded this in filings)	Thompson: Resentencing six years after termination was invalid because finality and lack of jurisdiction barred modification	Court: Trial court lacked jurisdiction; resentencing entry vacated and judgment reversed

State v. Holdcroft, 1 N.E.3d 382 (Ohio 2013) (announced principle that a court generally cannot modify a sentence once the prison portion has been fully served)
State v. Harper, 159 N.E.3d 248 (Ohio 2020) (reaffirmed traditional void/voidable distinctions and limited some postconviction resentencing remedies)
State v. Fischer, 942 N.E.2d 332 (Ohio 2010) (discussed res judicata and correction of void sanctions in sentencing)
Ex parte Perry, 226 N.E.2d 104 (Ohio 1967) (explained void-judgment principles applicable to jurisdiction)