Ohio Supreme Court clarifies requirements for trial court "final orders"

In a case involving conflicting interpretations of an Ohio criminal rule of procedure, the Ohio Supreme Court last Wednesday held that:
“A trial court’s judgment of conviction in a criminal case is a ‘final’ order subject to review by a court of appeals under ORC § 2505.02 when the judgment sets forth (1) the guilty plea, jury verdict, or finding of the court upon which the conviction is based; (2) the sentence; (3) the signature of the judge who heard the case; and (4) the time stamp showing the journalization by the clerk of courts.” (Court’s summary)(Decision).

In a case originating in Summit County, the Ninth District Ohio Court of Appeals granted the state’s motion to dismiss on the basis that the trial court’s judgment entry didn’t meet the requirements of Criminal Rule 32(C), holding that “the order was not a ‘final, appealable order eligible for appellate review under ORC §2505.02 because it lacked a statement regarding the defendant’s plea. The Court subsequently also certified its ruling to be in conflict with a 2002 ruling the 12th. District Ohio Court of Appeals had made.

The Supreme Court in its holding, Wednesday, “rejected both the 9th. District’s holding that CrimR 32© requires every judgment of conviction to indicate the defendant’s plea at arraignment, and the 12th. District’s holding back in 2002, that the requirements of the rule need not be met in a single document as long as the required information is available elsewhere in the trial record.”