State v. Grimes
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To validly impose postrelease control when the trial court orally provides all the required advisements at the sentencing hearing, the sentencing entry must contain certain required information.
In 2011, the court of common pleas imposed postrelease control on Defendant as part of his sentence of convictions for robbery and vandalism. While Defendant was under postrelease control, he pled guilty to unlawful sexual conduct with a minor. The trial court sentenced Defendant to a one-year prison term and imposed a judicial-sanction sentence converting the remainder of the postrelease-control term imposed for his 2011 conviction into prison time. After Defendant completed his prison term for unlawful sexual conduct with a minor, he moved the trial court to vacate his judicial-sanction sentence and order his release from prison, arguing that the court did not validly impose postrelease control when it sentenced him for his 2011 convictions. The trial court denied the motion. The court of appeals reversed. The Supreme Court reversed and reinstated the trial court’s judgment, holding that the sentencing entry in this case included all of the required information.
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