In State v. Boswell, 121 Ohio St.3d 575, 2009 Ohio 1577, 906 N.E.2d 422, a defendant pleaded guilty to offenses requiring a mandatory term of postrelease control. At the plea hearing, the trial court advised Boswell that he may be subject to postrelease control; however, the trial court did not explain postrelease control. Additionally, the sentencing entry did not impose postrelease control. Five years after his conviction and sentencing, Boswell filed a motion to vacate his plea on the basis that the trial court had not informed him of postrelease control during the plea hearing, which the trial court granted and appeals court affirmed. Thereafter, the Supreme Court accepted a discretionary appeal from the State, affirming the lower courts' decisions. The Supreme Court found that, because Boswell's sentence failed to impose the mandatory term of postrelease control required by statute, it was void. Id. at PP8, 13. The Court then concluded that, because the sentence was void, it must be vacated, and required Boswell's motion to be treated as a presentence motion to withdraw his guilty plea. Id. at P10. Notably, the Court declined to address whether Boswell's motion was barred by res judicata, as the State failed to raise that issue in any proposition of law. Id. at P10. In conclusion, the trial court held "pursuant to Crim.R. 32.1, that a defendant's motion to withdraw a guilty plea following the imposition of a void sentence must be considered as a presentence motion and be freely and liberally granted." Id. at P13.