State v. Walker, 2019 Ohio 605

In 1990 Anthony Maurice Walker pled guilty to aggravated murder (with death specification), rape, and aggravated burglary and was sentenced to life with parole eligibility after 30 years for murder and 10–25 years on other counts; no direct appeal was taken.
In 2017 Walker filed multiple motions: a "Motion to Arrest Judgment" (claiming no complaint issued), a motion asserting his sentence was void/there was no final appealable order, and a "Motion for Relief from: 'Dormant Judgment'" arguing his aggravated-murder sentence was inconsistent/indefinite and therefore void, making the costs judgment dormant.
The trial court denied the sentencing-related motions; Walker appealed and this Court previously held many sentencing arguments were barred by res judicata because he did not pursue a direct appeal.
The trial court later denied the remaining motions (including the "Dormant Judgment" motion); Walker appealed that denial to this Court.
The Ninth District construed Walker’s "Dormant Judgment" motion as a petition for postconviction relief under R.C. 2953.21, found it untimely (filed long after the applicable deadline for those sentenced before the 1995 amendment), and concluded Walker did not meet the statutory thresholds to file an untimely petition.
The Court affirmed the trial court’s denial and taxed costs to Walker.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Walker’s life sentence with parole eligibility after 30 years is internally inconsistent/void	Walker: The phrasing ("remainder of his natural life, with parole eligibility after 30 full years") creates conflicting/indefinite sentence and is void	State: The sentence is not void; this claim was previously rejected and is barred by res judicata because no direct appeal was taken	Court: Overruled Walker’s challenge as already decided on prior appeal; claim barred by res judicata
Whether the costs judgment is "dormant" and whether the "Dormant Judgment" motion was timely/entitles relief	Walker: If the sentence is void, the judgment for costs is dormant under R.C. 2325.15 and cannot be revived without a show-cause hearing	State: The motion is properly treated as a postconviction petition; it is untimely and Walker failed to meet the statutory exceptions for untimely petitions	Court: Construed the motion as a postconviction petition; it was untimely for a 1990 sentence and Walker failed to satisfy R.C. 2953.23; denial affirmed

State v. Schlee, 117 Ohio St.3d 153 (2008) (courts may construe irregular filings to the substantive relief asserted to identify applicable standards)
State v. Reynolds, 79 Ohio St.3d 158 (1997) (discusses construction of postconviction claims and related standards)