Mansaray v. State
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In 2010, Appellee was convicted of a drug offense and a related offense and sentenced to eleven years in prison. In late 2010, Appellee’s convictions were reversed. Appellee was released on bond and the charges against him were dismissed. Appellee then filed a complaint asserting that he was a wrongfully imprisoned individual. The trial court dismissed the complaint, but the court of appeals reversed, concluding that Appellee satisfied all five requirements of Ohio Rev. Code 2743.48(A)(1) through (5). The Supreme Court reversed, holding (1) when a defendant seeks a declaration that he is a wrongfully imprisoned individual and seeks to satisfy subsection 2743.48(A)(5) by proving that an error in procedure resulted in his release, the error in procedure must have occurred subsequent to sentencing and during or subsequent to imprisonment; and (2) Appellee did not satisfy subsection 2743.48(A)(5) in this case.
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