State v. Taylor

In State v. Taylor (1996), 78 Ohio St.3d 15, 23, 1997 Ohio 243, 676 N.E.2d 82, the Ohio Supreme Court found that the trial court "clearly had authority" to utilize a nunc pro tunc order to correct a factual error in a judgment entry entered 19 years earlier. In Taylor, Michael Taylor had pled guilty to, and was convicted of, two murders in 1974. The 1974 journal entry stated that he had been convicted of attempted murder. Id. In 1982, Taylor's prison sentence was commuted and he was released from jail. Id. at 24. In 1993, while on trial for another murder, the prosecutor secured a nunc pro tunc order to correct the 1974 judgment entry, thus allowing the jury to convict him of the 1992 aggravated murder with a death penalty specification for a prior murder conviction. Id. at 23.