State v. Brasher

Citations

• 170 N.E.3d 920
• 2021 Ohio 1688

Syllabus

The trial court erred by issuing a supplemental sentencing entry ordering appellant to pay restitution. Because he had already been released from prison, appellant had a reasonable expectation in the finality of his sentence and the trial lacked jurisdiction to issue the supplemental sentencing entry. As a result, the supplemental sentencing entry ordering restitution is void consistent with the Ohio Supreme Court's decision in State v. Holdcroft, 137 Ohio St.3d 526, 2013-Ohio-5014, as well as the new \realignment\ in the void-versus-voidable jurisprudence outlined in State v. Harper, 160 Ohio St.3d 480, 2020-Ohio-2913.