State v. Wilson, 2013 Ohio 1529

Wilson pleaded guilty in 2010 to failing to register address under Megan’s Law after a 1999 conviction for robbery and attempted rape.
He was sentenced to four years in prison with the sentence suspended pending two years of community control.
The indictment alleged a second-degree felony under R.C. 2950.99 for his failure to report a change of address.
While on community-control proceedings, Wilson moved to withdraw his guilty plea; the trial court denied the post-sentence motion on November 7, 2011.
An appeal from the denial was pursued via delayed appeal; the court ultimately affirmed the denial and overruled the assignment of error; there is a dissent referencing potential post‑Megan’s Law/Adam Walsh Act considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the post-sentence motion to withdraw the guilty plea was correctly denied.	Wilson argued the penalties were incorrect under Megan’s Law, making the plea unknowingly entered.	The State contends res judicata bars relief since the issue could have been raised on direct appeal.	Denied; res judicata bars the post-sentence withdrawal claim.

State v. Saxon, 109 Ohio St.3d 176 (2006-Ohio-1245) (res judicata applies to issues that could be raised on direct appeal)
State v. Hutton, 100 Ohio St.3d 176 (2003-Ohio-5607) (limits on post-sentence motions and res judicata implications)
State v. D’Ambrosio, 73 Ohio St.3d 141 (1995-Ohio-143) (res judicata and post-plea claims)
State v. Abuhilwa, 2012-Ohio-3441 (9th Dist. No. 26183) (res judicata bars collateral claims raised after conviction)
State v. Gorospe, 2011-Ohio-3291 (9th Dist. Nos. 25551, 25552) (bar on post-plea errors available on direct appeal)
State v. Molnar, 2011-Ohio-3799 (9th Dist. No. 25267) (res judicata and post-sentence withdrawal context)
State v. Ketterer, 2010-Ohio-3831 (Ohio Supreme Court 2010) (principles governing withdrawal of guilty pleas)