State v. Brown

Citations

• 2023 Ohio 4436

Syllabus

Where the statement of community control violations was filed and a hearing date was set prior to expiration of the term of community control, the trial court had authority to conduct the community control revocation proceeding. However, the trial court erred in failing to engage in the appropriate colloquy with the unrepresented defendant regarding his constitutional right to counsel and whether he intended to waive that right before revoking his community control and imposing the balance of the suspended jail sentence.