The Ohio Supreme Court held in State v. Baker, 2008-Ohio-3330, that a final appealable order had to contain what the conviction was based upon, the sentence, and the judge's signature and they all had to be in one document that the clerk of the court had to enter upon the journal. But today the Ohio Supreme Court pointed out in State v. Ketterer, 2010-Ohio-3831, that State v. Baker only applies to non-capital cases. In aggravated-murder cases subject to R.C. 2929.03(F) (which requires the court to file a separate sentencing entry), the final appealable order can consist of more than one document - the sentencing opinion and the judgment of conviction. Read the decision here or review the oral argument here.
Final Appealable Orders and the "one document" rule
August 25, 2010
