State v. Ward, 2011 Ohio 6382

Ward was convicted in 2004 on no-contest pleas to drug possession and drug trafficking in Hamilton County; sentences imposed.
Ward unsuccessfully challenged those convictions on direct appeal and in the Ohio Supreme Court.
In February 2010 Ward moved in the Common Pleas Court to correct his judgment of conviction, arguing the sentences were void for improper postrelease-control notification.
The Supreme Court in Bloomer held that sentencing courts must notify the offender of the mandatory nature and length of postrelease control and record that notification in the judgment entry.
For first-degree felonies here, the trial court was required to include a mandatory five-year postrelease-control period; failure makes the sentence void.
The trial court declined Ward’s request for resentencing, the sentences were void to the extent of postrelease-control noncompliance, and the matter was remanded for proper imposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ward's sentences were void for failure to notify about postrelease control	Ward	Ward	Yes, sentences void; remand for correction

State v. Bloomer, 122 Ohio St.3d 200 (Ohio Supreme Court, 2009) (mandatory postrelease-control notification must be included in the judgment)
State v. Fischer, 128 Ohio St.3d 92 (Ohio Supreme Court, 2010) (offending portion of sentence subject to correction)
State v. Copeland, 2011-Ohio-6034 (First District, 2011) (postrelease-control notification requirements and corrections on appeal)
State v. Jordan, 104 Ohio St.3d 21 (Ohio Supreme Court, 2004) (mandate of five-year postrelease-control term for first-degree felonies)