State v. Walker, 2021 Ohio 580

Jalen Walker was involved in two separate 2018 incidents: a police chase (Aug. 2) and a Euclid apartment shooting (Oct. 14) that resulted in a death.
He was indicted in two Cuyahoga County cases and, on Aug. 19, 2019, pled guilty to multiple counts including attempted murder (which classifies as a violent-offender predicate under Sierah’s Law).
At the plea hearing the court told Walker there was a duty to enroll in the violent offender database (VOD), but did not give the full statutory advisements required to be given before sentencing.
At sentencing (Sept. 26, 2019) the court announced the full advisements, held a brief enrollment hearing, and ordered Walker to enroll in the VOD despite the prosecutor conceding Walker was not the principal offender for the attempted murder.
Walker appealed, arguing (1) the court failed to give required pre-sentencing notice and (2) retroactive application of Sierah’s Law is unconstitutional; the appellate court vacated the VOD order and remanded for a new, compliant hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with R.C. 2903.42(A)(1)(a) notice requirement before sentencing	Court’s statements at plea and at sentencing were adequate	Notice was insufficient because full statutory advisements were not given before sentencing and Walker had no time to file a rebuttal motion	Vacated enrollment: trial court failed to give the pre-sentencing statutory advisements; remand for proper advisements and hearing
Whether retroactive application of Sierah’s Law violates Ohio’s Retroactivity Clause / is punitive	State would defend law as constitutionally permissible (remedial/public-safety)	Applying VOD retroactively is punitive and violates Section 28, Article II and ex post facto principles	Court declined to address merits: Walker forfeited the constitutional challenge by not raising it below; assignment overruled but case remanded on notice/presumption grounds

In re Gault, 387 U.S. 1 (U.S. 1967) (notice must set forth specific issues a party must address to satisfy due process)
State ex rel. Johnson v. Cty. Court of Perry Cty., 25 Ohio St.3d 53 (Ohio 1986) (notice must contain sufficient particularity to afford meaningful opportunity to defend)
State v. Wilkinson, 64 Ohio St.2d 308 (Ohio 1980) (notice must provide a party with time to prepare)
State v. Awan, 22 Ohio St.3d 120 (Ohio 1986) (failure to raise statutory or constitutional challenge at trial is forfeiture)
State v. Quarterman, 140 Ohio St.3d 464 (Ohio 2014) (appellate courts may, in limited circumstances, review forfeited constitutional issues)