State v. Farley

Citations

• 2024 Ohio 3238

Syllabus

Crim.R. 11 is not applicable to revocation proceedings. However, a community control revocation proceeding must nonetheless comport with the requirements of due process. In this case, the trial court fully complied with Crim.R. 32.3 and appellant was provided with due process in the revocation of his community control. Appellant's attempt to alter the results of a drug test, continued use of methamphetamine, and his failure to make any payments toward his ordered restitution were nontechnical violations of his community control authorizing the trial court to impose a sentence in excess of the 180-day limitation sent forth in R.C. 2929.15(B)(1)(c)(ii). However, appellant's sentence is modified as the prison term exceeds the term reserved at the original sentencing hearing.