State v. Woods

Summary

The Sixth District Court of Appeals affirmed Marcus Woods’s convictions and sentence for attempted trespass in a habitation and a prison sanction for committing a felony while on postrelease control. The court held that Woods had not identified a reviewable trial-court error concerning the Ohio Adult Parole Authority’s calculation of his remaining postrelease-control term. The court remanded for a nunc pro tunc entry consolidating the felony sentence and postrelease-control sanction into a single judgment entry.

Holdings

1. The court could not grant relief because Woods failed to identify a trial-court error in the record; the alleged miscalculation was attributable to the Adult Parole Authority rather than the sentencing court.
2. The appellate court could not consider documents or emails attached to the briefs that were not part of the trial-court record.
3. The trial court erred by memorializing the sentence in two separate judgment entries; the sentence under R.C. 2929.141 is part of the sentencing in the underlying felony case and must be reflected in a single final judgment entry.
4. The matter should be remanded for a nunc pro tunc order correcting the judgment entry to reflect both prison terms in a single entry for case No. 2021CR1683.

Questions Presented

1. Whether the trial court committed reversible error by imposing a 452-day prison term based on the Adult Parole Authority's calculation of the remaining postrelease-control period.
2. Whether documents and information attached to the parties' appellate briefs, but not included in the trial-court record, could establish error on direct appeal.
3. Whether the trial court erred by memorializing the new-felony sentence and the postrelease-control sanction in separate judgment entries.

Disposition

affirmed_and_remanded