State v. Zack, 2011 Ohio 4882

In 1998, Zack was convicted by a jury of multiple sexual offenses and bribery, which this Court affirmed on direct appeal.
In 2010, Zack moved for a final appealable order arguing Crim.R. 32(C) required a sentencing entry detailing the manner of conviction.
The trial court granted the motion on December 21, 2010, but did not reissue the entire sentencing entry; instead it amended nunc pro tunc to add that Zack appeared for sentencing after a jury verdict.
Zack appeals only from the December 21, 2010 nunc pro tunc entry, challenging its form.
The appellate court dismisses the appeal for lack of jurisdiction, holding the nunc pro tunc entry corrected a clerical error and did not affect a substantial right or create a final, appealable order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the nunc pro tunc entry is a final appealable order	Zack argues the court failed Crim.R. 32(C) compliance and issued an improper nunc pro tunc entry.	The court reasoned the nunc pro tunc entry corrected a clerical error and did not create a final, appealable order.	No final, appealable order; appeal dismissed for lack of jurisdiction.

State v. Muncie, 91 Ohio St.3d 440 (2001) (defines final order and R.C. 2505.02 standards)
State v. Battle, 2007-Ohio-2475 (2007) (nunc pro tunc corrections reflect what court actually decided)
State ex rel. DeWine v. Burge, 128 Ohio St.3d 236 (2011) (clerical error in sentencing and nunc pro tunc remedy)
State v. Plant, 2008-Ohio-4424 (2008) (nunc pro tunc entries relate back to journal entry date)
State v. McClanahan, 2010-Ohio-5825 (2010) (nunc pro tunc corrections and timing)
State v. Lester, 2010-Ohio-4739 (2010) (dismissal where nunc pro tunc did not affect substantial rights)
State v. Harvey, 2010-Ohio-1628 (2010) (nunc pro tunc corrections to Crim.R. 32(C) issues; no new right)