State v. Watson, 2021 Ohio 2773

Maurice Watson was convicted after a bench trial of multiple counts including aggravated robbery, felonious assault, discharge of a firearm near prohibited premises, and having weapons while under disability.
He was sentenced to an aggregate term of 22 years (sentenced May 30, 2019; resentenced June 17, 2019).
Watson filed a delayed direct appeal on September 24, 2019; his convictions and sentence were ultimately affirmed.
On November 12, 2020 Watson filed a petition for postconviction relief alleging ineffective assistance of trial counsel (insufficient cross-examination of detectives) and failure to preserve exculpatory evidence.
The trial court summarily denied the petition on November 16, 2020 without making findings of fact or conclusions of law. Watson appealed, arguing the court erred by failing to issue the statutorily required findings because his petition was timely.
The appellate court held Watson’s petition was untimely (365 days from the expiration of the time for filing a direct appeal), so the court was not required to issue findings; the denial was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by dismissing the postconviction petition without findings of fact and conclusions of law	State: No error — the petition was untimely, and courts have no duty to issue findings for untimely petitions	Watson: Petition was timely — 365 days runs from the filing of the trial transcript in his delayed appeal (Nov 12, 2019), so his Nov 12, 2020 filing was timely	Court held petition untimely; deadline is 365 days from expiration of time to file direct appeal (July 16, 2020); no duty to issue findings for untimely petitions; judgment affirmed

State v. Howard, 59 N.E.3d 685 (10th Dist. 2016) (timeliness requirements for postconviction petitions are strictly enforced)
State v. Fields, 736 N.E.2d 933 (8th Dist. 1999) (filing a delayed appeal does not toll the statutory deadline to file a postconviction petition)