State v. Elliot

Citations

• 2023 Ohio 1459

Syllabus

COMMUNITY CONTROL – R.C. 2929.15 – R.C. 2929.19 – GUILTY PLEA: Where defendant pled guilty to a community-control violation, defendant was precluded from challenging the sufficiency of the evidence supporting the violation. Where defendant was found guilty of nontechnical community-control violations for failing to comply with court-ordered treatment and failing to pay restitution, the trial court was not required to comply with the requirement in R.C. 2929.15(B)(1)(c)(ii) that it impose a sentence of not more than 180 days. Where the trial court informed defendant of the range from which a prison term could be imposed for a violation of community control, and where defendant failed to appeal both the trial court's initial imposition of community control and the trial court's reinstatement of community control following a violation, defendant suffered no prejudice from the trial court's failure to comply with the requirement in R.C. 2929.19(B)(4) to inform him that, if he were to violate his community control, commit a violation of any law, or leave the state without permission from the court or his probation officer, the court could impose a longer time under the same community-control sanction, impose a more restrictive community-control sanction, or impose a prison term.