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STATE v. HOLDCROFT

Nos. 2012-1325 and 2012-1441.

137 Ohio St.3d 526 (2013)

2013-Ohio-5014

1 N.E.3d 382

THE STATE OF OHIO, Appellee, v. HOLDCROFT, Appellant.

Supreme Court of Ohio.

Decided November 20, 2013.

Attorney(s) appearing for the Case

Jonathan K. Miller , Wyandot County Prosecuting Attorney, for appellee.

Kristopher A. Haines , Assistant Ohio Public Defender, for appellant.

O'DONNELL and KENNEDY, JJ., dissent and would affirm the judgment of the court of appeals.

O'NEILL, J.

{¶ 1} In this case, we must again consider when a trial court has the authority to correct a sentence when one of the sanctions originally imposed by the trial court is void. We hold that a trial court cannot add a term of postrelease control as a sanction for a particular offense after the defendant has already served the prison term for that offense, even if the defendant remains in prison for other offenses.

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