State v. Smith

Citations

• 2025 Ohio 1277

Syllabus

The trial court did not err in overruling appellant's post-conviction motion for a \plain error analysis.\ The trial court did not modify his sentence without his presence in violation of Crim.R. 43. Instead, the Ohio Department of Rehabilitation and Correction administratively recalculated appellant's sentences and parole hearing date based on State ex rel. Fraley v. Ohio Dept. of Rehab. & Corr., 2020-Ohio-4410. The administrative recalculation resulted in a three-year reduction in appellant's sentences, consistent with the sentences the trial court originally imposed. Appellant was not entitled to have counsel appointed. Judgment affirmed.