Must Trial Court's Sentencing Entry Note Forfeiture Requirement In Order to Be 'Final, Appealable Order?'

8th District Court of Appeals (Cuyahoga County)

ISSUES:

* When a trial court's judgment of conviction in a criminal case includes a specification that the defendant must forfeit to the state certain property used in commission of his crime(s), but the journal entry recording the defendant's sentence does not include any reference to the forfeiture, is the sentencing order a "final" order subject to immediate appeal notwithstanding that omission, or does the omission of the forfeiture deprive a court of appeals of jurisdiction to review the case until it has been remanded to the trial court for resentencing?

* When the sentence imposed on a defendant for a criminal offense omits a driver license suspension that is mandatory for all persons convicted of that offense, does that omission render the defendant's sentence void and require a complete resentencing, or is the defendant entitled only to a new sentencing hearing limited to the issue of the license suspension?