State v. Angers

Citations

• 207 N.E.3d 1269
• 2023 Ohio 369

Syllabus

Violation of community-control sanctions driver's license suspension. Under R.C. 2929.15(B), when a defendant violates the conditions of his or her community control, a trial court has the option of imposing a longer period of community control, a more restrictive community-control sanction, or a prison term of any length within the range of that available for the original offense, up to the maximum that the trial court specified at the first sentencing hearing. A driver's license suspension under R.C. 2925.22 is part of a defendant's prison sentence it is not a community-control sanction. Thus, the suspension should have been imposed, if at all, at the original sentencing hearing. The trial court's imposition of a driver's license suspension for a violation of community-control sanctions is contrary to law.