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State v. Bollar

2026-08-20

Summary

Holding. The Court of Appeals affirmed the trial court's judgment, holding that the trial court did not err in denying Bollar's motion without addressing its merits because the law-of-the-case doctrine prevented reconsideration of the sentencing issue already decided by the Ohio Supreme Court, the motion was an untimely postconviction relief petition that failed to meet statutory exceptions and was barred by res judicata, and the nunc pro tunc entry properly clarified the sentence without changing it.

Marquis Bollar appealed the trial court's denial of his pro se motion to vacate his sentence, arguing the same firearm specification stacking issue that the Ohio Supreme Court had already decided against him in 2022. The trial court denied his motion without addressing its merits, and the Court of Appeals found this was proper because the law-of-the-case doctrine barred reconsideration of issues already resolved by the Supreme Court. Additionally, Bollar's motion was an untimely petition for postconviction relief that failed to meet the statutory exceptions, and it was further barred by the doctrine of res judicata since Bollar had raised the sentencing challenge in his direct appeal.

Bollar also challenged the trial court's use of a nunc pro tunc entry to clarify his sentence. The appellate court examined both the original and corrected judgment entries and found the nunc pro tunc entry accurately reflected the sentence imposed during the plea hearing—it merely clarified that the indefinite sentence for the underlying offenses was separate from the sentence for the firearm specifications that Bollar was required to serve first. Since nothing about the aggregate sentence changed and Bollar suffered no prejudice, any error in issuing the nunc pro tunc entry was found harmless.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether law-of-the-case doctrine bars a trial court from reconsidering a sentencing issue already decided by the Ohio Supreme Court
  • Whether an untimely petition for postconviction relief can be heard when statutory exceptions under R.C. 2953.23(A) are not satisfied
  • Whether a nunc pro tunc entry that clarifies but does not change a sentence constitutes harmless error
  • Whether firearm specifications attached to merged felony offenses are subject to consecutive sentencing under R.C. 2929.14(B)(1)(g)

Procedural posture

Bollar appealed the trial court's March 12, 2026 judgment denying his pro se motion to vacate sentence, which the trial court had characterized as an untimely petition for postconviction relief that raised issues already resolved in his 2021 direct appeal and subsequently affirmed by the Ohio Supreme Court in 2022.

Authorities cited

Opinion

majority opinion

[Cite as State v. Bollar, 2026-Ohio-3251.]

IN THE OHIO COURT OF APPEALS

FIFTH APPELLATE DISTRICT

STARK COUNTY, OHIO

STATE OF OHIO Case No. 2026CA00065

Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Court of Common Pleas, Case

No. 2019-CR-1620

MARQUIS L. BOLLAR

Judgment: Affirmed

Defendant - Appellant

Date of Judgment Entry: August 20, 2026

BEFORE: Andrew J. King; William B. Hoffman; Robert G. Montgomery, Judges

APPEARANCES: KYLE L. STONE, CHRISTOPHER A. PIEKARSKI, for PlaintiffAppellee; MARQUIS L. BOLLAR, PRO-SE, for Defendant-Appellant.

King, P.J.

{¶ 1} Defendant-Appellant Marquis Bollar appeals the March 12, 2026 Judgment of

the Stark County Court of Common Pleas which denied his Pro Se Motion to Vacate Sentence

Imposed Contrary to Law. Plaintiff-Appellee is the State of Ohio.

Facts and Procedural History

{¶ 2} This matter comes before us for a second time. In State v. Bollar, 2021-Ohio1578 (5th Dist.) we set forth the background of Bollar's case:

{¶ 3} On October 17, 2019, the Stark County Grand Jury returned a four-count

indictment charging Bollar as follows:

{¶ 4} Count one — felony murder;

{¶ 5} Count two — involuntary manslaughter;

{¶ 6} Count three — felonious assault;

{¶ 7} Count four — having weapons under disability.

{¶ 8} Each count of the indictment contained a firearm specification.

{¶ 9} On March 6, 2020, the state dismissed count one of the indictment and Bollar

entered pleas of guilty to counts two through four and the attendant gun specifications.

{¶ 10} During the sentencing hearing Bollar argued, and the state did not dispute that

counts two and three, involuntary manslaughter and felonious assault merged for purposes of

sentencing but having weapons under disability did not. Transcript of Plea and Sentencing

(T.) 30, 32, 34.

{¶ 11} The state argued, however, R.C. 2929.14(B)(1)(g) required two of the three gun

specifications to run consecutively to one another and consecutive to the underlying charge.

T. 29-30. Counsel for Bollar disagreed, and advanced an allied offenses argument — that all

three specifications were the result of one act by one person and therefore only one gun

specification could be imposed. T. 35

{¶ 12} After taking a recess to consider matters presented during Bollar's plea as well

as the application of R.C. 2929.14(B)(1)(g), the trial court sentenced Bollar to a minimum

mandatory sentence of 11 years for involuntary manslaughter. The court additionally

imposed three years for the attendant firearm specification and ordered Bollar to serve that

sentence prior to any other sentence. T. 51.

{¶ 13} While the trial court imposed no sentence for the merged felonious assault, it

found it was required to impose the attached gun specification and sentenced Bollar to three

years on the specification. T. 51.

{¶ 14} For having weapons under disability, the trial court imposed a thirty-sixmonth sentence and merged the attendant firearm specification. After making the appropriate

findings, the trial court ordered Bollar to serve this sentence consecutive to his sentence for

involuntary manslaughter and the two gun specifications for an aggregate minimum term of

20 years to a maximum term of 25.5 years. T. 52-54.

{¶ 15} Bollar filed an appeal and argued the trial court erred when it sentenced him to

three years for the firearm specification attendant to the charge of felonious assault after it

had merged the charges of involuntary manslaughter and felonious assault as allied offenses.

Bollar argued because the two charges merged, he could only be sentenced for one firearm

specification and therefore his sentence is contrary to law. We rejected Bollar's argument and

affirmed the trial court finding:

Bollar pled guilty to multiple felonies, to wit: involuntary manslaughter,

felonious assault and having weapons while under a disability. The

determination of guilt based upon his guilty pleas to each offense

survived the trial courts merger of the felonious assault and involuntary

manslaughter offenses. State v. Whitfield, 124 Ohio St.3d 319, 2010-Ohio-2, 922 N.E.2d 182. Therefore, the trial court was required by R.C.

2929.14(B)(1)(g) to sentence Bollar to the two most serious firearm

specifications that accompanied his felony guilty pleas. R.C.

2929.14(B)(1)(g).

We therefore find that the trial court did not err in concluding that the

firearm specifications accompanying the involuntary manslaughter and

felonious assault were not subject to merger pursuant to R.C.

2929.14(B).

The trial court did not err in ordering two of the three firearm

specifications to run consecutively pursuant to R.C. 2929.14(B)(1)(g).

{¶ 16} Id. at ¶¶ 28-30.

{¶ 17} Bollar filed a motion to certify a conflict to the Supreme Court of Ohio on the

question of "Whether Ohio's legislature has specifically authorized cumulative punishments

for multiple firearm specifications that were committed as part of the same act or transaction

under the narrowly tailored, specifically designated circumstances set forth in R.C.

2929.14(B)(1)(g), when the underlying felonies attendant to the firearm specifications are

merged at sentencing as allied offenses of similar import pursuant to R.C. 2929.14(C)(4)." We

certified the conflict, the Court determined a conflict existed and ordered briefing on the

certified question. State v. Bollar, 2021-Ohio-2795. The Court also accepted jurisdiction over

the sole proposition of law submitted in Bollar's discretionary appeal: "Trial courts cannot

impose a prison sentence for a specification attached to an offense that merged under R.C.

2941.25 and did not result in a conviction." Id.

{¶ 18} On December 9, 2022, the Court answered the certified question in the

affirmative, affirmed this court, and found "the plain language of R.C. 2929.14(B)(1)(g)

requires that offenders like Bollar receive separate prison terms for convictions on multiple

firearm specifications . . ." State v. Bollar, 2022-Ohio-4370, ¶ 26.

{¶ 19} On January 23, 2026, Bollar filed a motion in the trial court titled "Pro Se

Motion to Vacate Sentence Imposed Contrary to Law." In his motion, Bollar raised the same "unlawful firearm specification stacking" complaint he had raised before the Ohio Supreme

Court and further argued that because the firearm specifications were illegally stacked, his

minimum and maximum terms were miscalculated. The State filed a response arguing that

Bollar's motion was an untimely motion for postconviction relief.

{¶ 20} On February 23, 2026, the trial court issued a nunc pro tunc judgment entry

reiterating the calculation of Bollar's minimum and maximum terms but clarifying that the

indefinite sentence for the underlying offenses was separate from the sentence for the firearm

specifications which Bollar was required to serve prior to and consecutive to the indefinite

sentence for the underlying offenses. On March 12, 2026, via judgment entry the trial court

denied the balance of Bollar's argument.

{¶ 21} Bollar filed an appeal and the matter is now before this court for consideration.

He raises two assignments of error as follows:

I

{¶ 22} "THE TRIAL COURT ERRED BY DENYING THE APPELLANT'S

MOTION WITHOUT ADDRESSING THE MERITS."

II

{¶ 23} "IMPROPER USE OF NUNC PRO TUNC ENTRY."

I

{¶ 24} In his first assignment of error Bollar argues the trial court erred in denying his

motion without addressing the merits. We disagree.

Law of the Case

{¶ 25} We begin by noting that Bollar's motion presented the same consecutive

specification sentencing argument to the trial court that he had presented to the Supreme Court of Ohio in 2022. Law of the case doctrine provides that a decision of a reviewing court

in a case remains the law of the case on the legal questions involved for all subsequent

proceedings in the case at both the trial and reviewing levels. U.S. Bank v. Detweiler, 2012-Ohio-73, ¶ 26 (5th Dist.), citing Nolan v. Nolan, 11 Ohio St.3d 1 (1984).

{¶ 26} Because the Supreme Court of Ohio had already decided Bollar's challenge to

his sentence for the firearm specifications, the trial court was without authority to revisit the

matter and did not err in dismissing Bollar's motion without considering the merits of his

claim.

Post-Conviction Relief Principles

{¶ 27} Next although application of law of the case doctrine, standing alone, would

be sufficient grounds for the trial court to dismiss Bollar's motion, despite its caption, Bollar's

Pro Se Motion to Vacate Sentence Imposed Contrary to Law" was a motion for

postconviction relief. A motion filed subsequent to a defendant's direct appeal that claims a

denial of constitutional rights, seeks to render the judgment void, and asks that the judgment

be vacated is a motion for post-conviction relief. State v. Reynolds, 79 Ohio St.3d 158, 160

(1997).

{¶ 28} Although designed to address claimed constitutional violations, the

postconviction relief process is a civil collateral attack on a criminal judgment, not an appeal

of that judgment. State v. Calhoun, 86 Ohio St.3d 279, 281 (1999); State v. Steffen, 70 Ohio St.3d

399, 410 (1994). A petition for post-conviction relief does not provide a petitioner a second

opportunity to litigate his conviction, nor is the petitioner automatically entitled to an

evidentiary hearing on the petition. State v. Lewis, 2008-Ohio-3113, ¶ 8 (5th Dist.), citing State

v. Jackson, 64 Ohio St.2d 107, 110 (1980).

{¶ 29} Pursuant to R.C. 2953.21(A)(2), a petition for postconviction relief must be

filed no later than three hundred sixty-five days after the date on which the trial transcript is

filed in the court of appeals in the direct appeal of the judgment of conviction or adjudication.

If no appeal is taken, the petition must be filed no later than three hundred sixty-five days

after the expiration of the time for filing the appeal.

{¶ 30} A trial court is without jurisdiction to hear an untimely petition for

postconviction relief unless the petitioner meets exceptions contained in R.C. 2953.23(A).

Specifically, the petitioner must demonstrate:

(a) either the petitioner shows that the petitioner was unavoidably

prevented from discovery of the facts upon which the petitioner must

rely to present the claim for relief, or, subsequent to the period

prescribed in division (A)(2) of section 2953.21 of the Revised Code or

to the filing of an earlier petition, the United States Supreme Court

recognized a new federal or state right that applies retroactively to

persons in the petitioner's situation, and the petitioner asserts a claim

based on that right.

(b) the petitioner shows by clear and convincing evidence that, but for

the constitutional error at trial, no reasonable factfinder would have

found the petitioner guilty of the offense of which the petitioner was

convicted ...

{¶ 31} R.C. 2953.23(A)(1).

{¶ 32} Res judicata is also applicable to this matter. "Under the doctrine of res

judicata, a final judgment of conviction bars the convicted defendant from raising and

litigating in any proceeding, except an appeal from that judgment, any defense or any claimed

lack of due process that was raised or could have been raised by the defendant at the trial

which resulted in that judgment of conviction or on an appeal from that judgment." State v.

Perry, 10 Ohio St.2d 175 (1967), paragraph nine of the syllabus; Grava v. Parkman Twp., 73

Ohio St.3d 379 (1995), syllabus.

Bollar's Petition

{¶ 33} In this matter, Bollar's petition for postconviction relief was grossly untimely

and he failed to raise or argue that he met the requirements of R.C. 2953.23(A)(1). The trial

court was therefore without jurisdiction to consider the petition. Additionally, as discussed

above, Bollar challenged his sentence in his direct appeal. Bollar's sentencing challenge is

therefore barred by res judicata.

{¶ 34} The first assignment of error is overruled.

II

{¶ 35} In his final assignment of error, Bollar argues the trial court improperly used a

nunc pro tunc judgment entry because the nunc pro tunc entry is identical to the original

judgment entry.

{¶ 36} Crim.R. 36 grants power to a court to issue a nunc pro tunc entry to correct

"clerical mistakes in judgments, orders, or other parts of the record, and errors in the record

arising from oversight or omission, may be corrected by the court at any time." A clerical

mistake is a mistake or omission that does not involve a legal decision or judgment and is apparent from the record. State v. Miller, 2010-Ohio-5705, ¶ 15, citing State ex rel. Cruzado v.

Zaleski, 2006-Ohio-5795, ¶ 19.

{¶ 37} In its March 26, 2026 Judgment Entry the trial court's reasoning for issuing a

nunc pro tunc entry is unclear. The court stated: "Upon review of the motion, the Court

entered a nunc pro tunc judgment entry on February 23, 2026, to correct the calculation of

the indefinite sentence that was imposed in this case to indicate that the indefinite sentence is

separate from the calculation of the indefinite sentence." Judgment Entry, March 12, 2026,

docket item 85.

{¶ 38} We have therefore examined the two judgment entries in question. It appears

the trial court intended to indicate in its March 12, 2026 nunc pro tunc entry had corrected

the calculation of the underlying indefinite sentence to indicate that sentence was separate

from the calculation of the sentence for the gun specifications. (Compare Judgment Entry

Change of Plea and Sentence Imposed, March 17, 2020 at page 3-4, docket item 63, and

Change of Plea and Sentence Imposed Nunc Pro Tunc as of 3/17/2020, February 23, 2026,

docket item 83.) The aggregate prison sentence, however, did not change.

{¶ 39} We have further examined the transcript of plea and sentencing and find the

nunc pro tunc entry accurately reflects Bollar's sentence as imposed. Transcript at 52-53.

{¶ 40} While the nunc pro tunc in this instance appears to be a clarification rather than

a correction, we find any error in its issuance harmless because as Bollar observes, nothing

changed. He has therefore suffered no prejudice.

{¶ 41} The second assignment of error is overruled.

{¶ 42} The judgment of the Stark County Court of Common Pleas is affirmed. Costs

to Appellant.

By: King, P. J.

Hoffman, J. and

Montgomery, J. concur.