State v. Rarden

2025 Ohio 5798
CourtOhio Court of Appeals
DecidedDecember 30, 2025
DocketCA2025-03-027; CA2025-03-028
StatusPublished

This text of 2025 Ohio 5798 (State v. Rarden) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Rarden, 2025 Ohio 5798 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Rarden, 2025-Ohio-5798.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

BUTLER COUNTY

STATE OF OHIO, :

Appellee, : CASE NOS. CA2025-03-027 CA2025-03-028 : - vs - OPINION AND : JUDGMENT ENTRY 12/30/2025 LONNIE RARDEN, :

Appellant. :

CRIMINAL APPEAL FROM BUTLER COUNTY COURT OF COMMON PLEAS Case Nos. CR2006-07-1271; CR2006-09-1593

Michael T. Gmoser, Butler County Prosecuting Attorney, and John S. Heinkel, Assistant Prosecuting Attorney, for appellee.

Lonnie Rarden, pro se.

OPINION

BYRNE, P.J.

{¶ 1} Lonnie Rarden appeals from the decision of the Butler County Court of

Common Pleas, General Division, which denied his pro se motion for resentencing. For

the reasons discussed below, we affirm the trial court's decision. Butler CA2025-03-027 CA2025-03-028

I. Factual and Procedural Background

{¶ 2} In 2006, Rarden was indicted and charged with several felonies and

misdemeanors, including one count of felony escape, two counts of felony complicity to

perjury, and one count of felony complicity to tampering with evidence. A jury found

Rarden guilty of all charges and the trial court sentenced him to 26 and one-half years in

prison. This court affirmed Rarden's conviction and sentence on direct appeal and the

Ohio Supreme Court declined review. State v. Rarden, 12th Dist. Butler No. CA2007-03-

077 (Apr. 21, 2008) (Accelerated Calendar Judgment Entry); 05/05/2010 Case

Announcements, 2010-Ohio-1893.

{¶ 3} In the intervening years, Rarden has filed numerous postconviction motions

with the trial court seeking various relief. We summarized those efforts in a 2018 opinion.

State v. Rarden, 2018-Ohio-4487, ¶ 2-7 (12th Dist.).

{¶ 4} With relevance to this appeal, in March 2010, Rarden moved the court to

resentence him pursuant to R.C. 2929.191(A)(1). That statute governs the procedures for

holding a hearing and issuing a corrected judgment of conviction where the sentencing

court failed to properly notify an offender that, pursuant to R.C. 2967.28, he or she will be

subject to postrelease control upon leaving prison.

{¶ 5} In his motion, Rarden argued that, at sentencing in 2006, the trial court

informed him it would impose postrelease control, but it failed to inform him of the

consequences for violating postrelease control.

{¶ 6} On April 14, 2010, finding merit to Rarden's argument, the trial court held a

resentencing hearing limited to providing Rarden with the proper advisement and

imposition of postrelease control. On April 26, 2010, the court issued "re-sentencing

judgment of conviction" entries.

-2- Butler CA2025-03-027 CA2025-03-028

{¶ 7} Rarden appealed from those entries, arguing that the trial court erred by

confining the "re-sentencing" hearing solely to correcting the prior incorrect imposition of

postrelease control. This court overruled Rarden's assignment of error and affirmed the

trial court's decision and the Ohio Supreme Court declined review. State v. Rarden, 12th

Dist. Butler Nos. CA2010-04-095, CA2010-05-106, and CA2010-05-126 (Feb. 7, 2011)

(Accelerated Calendar Judgment Entry); 12/21/2011 Case Announcements, 2011-Ohio-

6556. Accord Rarden, 2018-Ohio-4487, ¶ 4. In our accelerated calendar judgment entry,

we noted Ohio Supreme Court precedent at the time, which held that when a court

improperly imposes postrelease control, only that portion of the sentence is void and

therefore only that portion is subject to vacation or amendment. Id. at ¶ 2. Thus, we held,

the trial court did not err in limiting the hearing to the proper imposition of postrelease

control. Id.

{¶ 8} Thirteen years later, in December 2024, Rarden filed the motion to

resentence at issue in this appeal. Rarden asked the trial court to resentence him de

novo, arguing that the trial court lacked subject-matter jurisdiction when it resentenced

him in 2010. He based this argument on his interpretation of two Ohio Supreme Court

cases: State v. Harper, 2020-Ohio-2913, and State v. Henderson, 2020-Ohio-4784.

Those cases address whether sentencing errors render a sentence void or voidable. The

gist of Rarden's argument was that the error in imposing postrelease control in his original

sentence made that sentence voidable, not void, and any error in imposing postrelease

control could only be raised and addressed through a direct appeal. Since Rarden had

not raised this issue in his direct appeal, he argued, his sentence was final once that

appeal was resolved and therefore the trial court lacked subject-matter jurisdiction to hold

the resentencing hearing that he requested in March 2010 and that the trial court held in

-3- Butler CA2025-03-027 CA2025-03-028

in April 2010.

{¶ 9} After Rarden's December 2024 motion for resentencing was fully briefed,

the common pleas court issued a decision denying Rarden's motion. The common pleas

court found that it had subject-matter jurisdiction to issue the corrected sentence in 2010

pursuant to the same statutory authority that Rarden cited in his March 2010 motion, i.e.,

R.C. 2929.191. The court further found that neither Ohio Supreme Court case cited by

Rarden supported the conclusion that the trial court lacked subject-matter jurisdiction to

hold the April 2010 hearing and issue a corrected sentence under R.C. 2929.191. The

court noted that neither case addressed R.C. 2929.191 or the question of subject-matter

jurisdiction in relation to the procedures set forth in R.C. 2929.191. The court also found

that Rarden's argument for resentencing was barred by res judicata.

{¶ 10} Rarden appealed, pro se, raising two assignments of error.

II. Law and Analysis

A. Jurisdiction to Modify Sentence

{¶ 11} Rarden's first assignment of error states:

THE TRIAL COURT DID NOT HAVE SUBJECT MATTER JURISDICTION TO MODIFY DEFENDANT'S SENTENCES TWO YEARS AFTER HIS DIRECT APPEAL BECAME FINAL.

{¶ 12} In his first assignment of error, Rarden argues that the trial court erred in

denying his December 2024 motion for resentencing and argues that two Ohio Supreme

Court cases—Harper and Henderson—compel the conclusion that the trial court lacked

subject-matter jurisdiction in April 2010 when it corrected the postrelease control portion

of his sentence.

{¶ 13} In Harper, the Ohio Supreme Court realigned it precedent in cases involving

the erroneous imposition of postrelease control with the traditional understanding of what

-4- Butler CA2025-03-027 CA2025-03-028

constitutes a void judgment. 2020-Ohio-2913 at ¶ 4. "That is to say, the Ohio Supreme

Court clarified its prior decisions discussing the void/voidable conundrum and explicitly

stated that '[w]hen a case is within a court's subject-matter jurisdiction and the accused

is properly before the court, any error in the exercise of that jurisdiction in imposing

postrelease control renders the court's judgment voidable,' not void." State v. Brasher,

2021-Ohio-1688, ¶ 17 (12th Dist.), quoting Harper at ¶ 4. "If a judgment entry is voidable,

then it must be challenged on direct appeal, or else principles of res judicata will apply . .

. ." State ex rel. Romine v. McIntosh, 2020-Ohio-6826, ¶ 12.

{¶ 14} In Henderson, the Ohio Supreme Court held that Harper was not limited to

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2025 Ohio 5798, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-rarden-ohioctapp-2025.