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State ex rel. Mack v. Collier

Citations: 2011 Ohio 4188; 129 Ohio St. 3d 497Docket: 2011-0719

Court: Ohio Supreme Court; August 30, 2011; Ohio; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

A writ of mandamus was sought by Jeffery Mack to compel Judge Christopher J. Collier of the Medina County Court of Common Pleas to conduct a de novo resentencing hearing due to an alleged error in the sentencing entry that violated Criminal Rule 32(C). The Supreme Court of Ohio affirmed the court of appeals' dismissal of Mack's petition, emphasizing that the proper remedy for non-compliance with Crim. R. 32(C) is a revised sentencing entry rather than a new hearing. This decision referenced prior cases, including State ex rel. Scheck v. Collier, which established that issues regarding post-release control could have been appealed and thus were not grounds for mandamus relief. Additionally, Mack's appeal for a revised sentencing entry was deemed waived since his original complaint only requested a resentencing hearing. The judgment was affirmed unanimously by the justices.

Legal Issues Addressed

Appealability of Post-Release Control Issues

Application: The court referenced past cases indicating that issues related to post-release control should be addressed through an appeal rather than mandamus relief, as they can be appropriately contested in appellate court.

Reasoning: This decision referenced prior cases, including State ex rel. Scheck v. Collier, which established that issues regarding post-release control could have been appealed and thus were not grounds for mandamus relief.

Mandamus Relief and Sentencing Errors

Application: The court determined that mandamus relief is not appropriate for addressing sentencing entry errors under Criminal Rule 32(C); instead, a revised sentencing entry is the correct remedy.

Reasoning: The Supreme Court of Ohio affirmed the court of appeals' dismissal of Mack's petition, emphasizing that the proper remedy for non-compliance with Crim. R. 32(C) is a revised sentencing entry rather than a new hearing.

Waiver of Claims Not Raised

Application: The court found that Mack waived his right to request a revised sentencing entry because his original complaint only sought a resentencing hearing, failing to explicitly request the revised entry.

Reasoning: Additionally, Mack's appeal for a revised sentencing entry was deemed waived since his original complaint only requested a resentencing hearing.