Patterson v. Ohio Adult Parole Auth

In Patterson v. Ohio Adult Parole Auth., 120 Ohio St. 3d 311, 2008 Ohio 6147, 898 N.E.2d 950, Patterson commenced a habeas corpus to contest his post-release control sanctions. He claimed that the trial judge failed to notify him of post-release control during the sentencing hearing, although the judge included it in the sentencing entry. The Supreme Court of Ohio upheld the dismissal of the habeas corpus action on the grounds of adequate remedy at law. "Patterson had an adequate remedy by way of direct appeal from his sentence to raise his claim that he did not receive proper notification about postrelease control at his sentencing hearing. E.g., Watkins v. Collins, 111 Ohio St.3d 425, 2006 Ohio 5082, 857 N.E.2d 78, P45 ('The remedy for improper notification about postrelease control at the sentencing hearing is resentencing-not release from prison') and P53 ('habeas corpus is not available to contest any error in the sentencing entries, and petitioners have or had an adequate remedy by way of appeal to challenge the imposition of postrelease control')." Patterson at P8.