State v. Trammell, 2016 Ohio 5200

In 2002 Trammell was convicted of receiving stolen property and sentenced to 11 months; court costs were imposed in the 2002 judgment and again in a 2003 revocation entry.
Trammell received judicial release in 2003, which was later revoked; he remained incarcerated on other matters until 2012.
In April 2012, after release, Trammell signed a court-approved payment plan agreeing to pay $20/month toward fines, costs, and restitution and made two payments.
The Stark County Clerk sent a statement to the correctional institution in December 2012 showing an outstanding balance; the institution began withdrawing funds from Trammell’s account in 2015.
Trammell filed a motion in December 2015 seeking relief from what he characterized as a revived dormant judgment and requested suspension and return of deducted funds; the trial court denied the motion in January 2016.
On appeal, Trammell argued the collection actions revived a dormant judgment without notice or a hearing (relying on State v. Magruder); the appellate court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Trammell)	Held
Whether collection from Trammell’s institutional account improperly revived a dormant judgment without notice or hearing	Collection and enforcement were valid because Trammell entered an agreed payment plan and did not seek relief in 2012	The judgment for costs had become dormant; its administrative/extra-judicial revival required notice and a hearing under due process (citing Magruder)	Court held no dormancy or improper revival: Trammell’s 2012 signed payment agreement and payments prevented dormancy, and he failed to timely challenge costs; Magruder is distinguishable
Whether the imposition/amount of court costs may be challenged now	Costs were validly imposed in 2002/2003 and enforcement in 2012 was appropriate	Challenges to imposition of costs are timely and required because of later deductions	Held that challenges to imposition are barred by res judicata because Trammell could have raised them on direct appeal and did not do so

State v. Perry, 10 Ohio St.2d 175 (1967) (establishes res judicata bar to litigating claims that could have been raised on direct appeal)
State v. Threatt, 843 N.E.2d 164 (Ohio 2006) (addresses res judicata principles in post-conviction/procedural context)