State v. Wright, 2023 Ohio 2134

Brooke M. Wright pled guilty to two counts of sexual battery (R.C. 2907.03) and was automatically classified as a Tier III sex offender; the February 5, 2021 judgment entry stated lifetime registration and that "community notification will be sent." She signed the Explanation of Duties form at sentencing.
Wright was sentenced to concurrent four-year terms, later granted judicial release and released from ODRC in February 2022.
On March 2, 2022 (after sentencing and after the judgment entry imposing notification), Wright moved for exemption from community notification under R.C. 2950.11(F)(2). The State opposed, arguing R.C. 2950.11(H) governs post-sentencing relief and requires a 20-year waiting period.
The trial court granted Wright's motion, concluding F(2) relief was timely because she sought exemption before her duty to register began.
The State appealed. The Tenth District reversed, holding R.C. 2950.11(F)(2) is available only at or before sentencing and post-sentencing relief is governed by R.C. 2950.11(H)(2) (which requires 20 years). The case was remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2950.11(F)(2) can be used to seek exemption from community notification after sentencing	F(2) applies only at or before sentencing; post-sentencing relief must proceed under H(2)	F(2) applies because she sought exemption before being required to register in the community (before release)	Court held F(2) is only available at or before sentencing; trial court erred in applying F(2) post-sentencing
Whether post-sentencing exemption must proceed under R.C. 2950.11(H)(2) (20-year threshold)	H(2) governs after conviction/sentencing; Wright cannot obtain exemption now because 20 years have not passed	H(2) is not relevant because she sought exemption before registry duties commenced on release	Court held H(2) governs post-sentencing relief and the 20-year statutory window applies; F(2) was inapplicable
Whether Wright forfeited challenge to notification by failing to raise it at sentencing (res judicata/waiver)	Wright could have sought an F(2) hearing at sentencing and failed to do so; objections at sentencing are waived absent plain error	Wright argued timely procedural posture for exemption because she moved before release/registration	Court noted Wright waived plain-error review by not invoking it and that challenges to notification generally must be raised at sentencing or on direct appeal; court reversed trial court for applying the wrong statutory route

State v. Twyford, 94 Ohio St.3d 340 (plain-error/waiver rules when defendant fails to object at sentencing)
State v. McConville, 124 Ohio St.3d 556 (interpretation of R.C. 2950.11(F)(2) and timing of community-notification hearings)
State v. Williams, 129 Ohio St.3d 344 (Tier III duties are punitive and mandatory except for community-notification discretion)
State v. Bonnell, 140 Ohio St.3d 209 ("a court speaks through its journal" and sanctions commence by journal entry)
State v. Dangler, 162 Ohio St.3d 1 (Crim.R. 11(C)(2)(a) and advising defendants of penalties)