State v. Ysrael, 2015 Ohio 332

Elijah Ysrael was convicted of cocaine trafficking in August 2010 and sentenced to four years' imprisonment; multiple prior appeals and remands occurred for fines and notifications.
He filed two postconviction-style motions: (1) August 2012 "Motion for Journalization of Amendment to Bill of Particulars"; (2) January 2014 "Motion for Resentencing Based on Void Judgment" challenging postrelease-control notification.
The Hamilton County Common Pleas Court overruled both motions in a single February 13, 2014 entry.
Ysrael appealed both rulings to the First District Court of Appeals.
The appeals court concluded the trial court lacked jurisdiction to entertain the August 2012 motion and therefore modified the judgment to dismiss it; the court found the January 2014 resentencing claim moot because the record showed Ysrael had been released from prison and there was no showing he remained subject to postrelease control.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Ysrael)	Held
Whether the trial court had jurisdiction to consider the Aug. 2012 motion to journalize an amendment to the bill of particulars	The motion was a postconviction claim filed after statutory time limits and did not meet late-filing prerequisites; thus court lacked jurisdiction	The motion sought relief (amendment) and should be considered on merits (characterized as non-void-judgment relief)	Court held the motion was effectively a postconviction claim filed too late and the error alleged did not render the conviction void; trial court lacked jurisdiction — judgment modified to reflect dismissal
Whether the challenge to postrelease-control notification (Jan. 2014 motion) required resentencing/correction	The appeal is moot because Ysrael had completed his prison term and the record contains no proof he is subject to postrelease control, so no remedy is available	The sentencing notification at the hearing misstated postrelease-control duration; that portion of the sentence is void and must be corrected — remand required; appeal not moot absent proof he finished postrelease control	Court held the trial court would have had jurisdiction to correct a void postrelease-control sentence, but because Ysrael had been released and the record did not show he was on postrelease control, the appeal from denial of relief is moot and is dismissed

State v. Fischer, 128 Ohio St.3d 92 (void postrelease-control portion of sentence may be reviewed and corrected)
State v. Bloomer, 122 Ohio St.3d 200 (correction of void postrelease-control portion is unavailable after offender's release in certain contexts)
State ex rel. Cruzado v. Zaleski, 111 Ohio St.3d 353 (court always has jurisdiction to correct a void judgment)
State v. Schlee, 117 Ohio St.3d 153 (characterizing certain claims as subject to postconviction statutes)
State v. Golston, 71 Ohio St.3d 224 (convicted felons retain substantial stake in conviction after sentence completion)
State v. Berndt, 29 Ohio St.3d 3 (appeal moot when sentence completed absent collateral disability showing)
Fortner v. Thomas, 22 Ohio St.2d 13 (courts decide actual controversies capable of effective relief)
Spencer v. Kemna, 523 U.S. 1 (federal mootness principles; no power to act when case is moot)