State v. Conn

Citations

• 2020 Ohio 2757

Syllabus

CRIMINAL-POST RELEASE CONTROL NOTIFICATION - The trial court's use of the phrase \up to\ rather than \a period of\ when imposing a mandatory five-year term of post-release control did not render the imposition of post-release control void where the totality of the circumstances indicate the appellant was placed on notice he was subject to a mandatory term of five years of post-release control. In considering the totality of the circumstances concerning a trial court's imposition of post-release control, reviewing courts may look to other documents, such as plea agreements, sentencing hearing transcripts, and judgment entries that alone may be insufficient to properly impost post-release control.