State v. Garland

Citations

• 2020 Ohio 6712

Syllabus

AUTOS/CRIMINAL – OVI – R.C. 4510.46 – DOUBLE JEOPARDY – IGNITION-INTERLOCK-DEVICE VIOLATION: The trial court erred in increasing defendant's license suspension to seven years where the court originally suspended defendant's license for three years for operating a motor vehicle while under the influence of alcohol, and, pursuant to R.C. 4510.46(C)(3), the court was only permitted to increase defendant's license suspension by a factor of two upon defendant's ignition-interlock-device violation. The trial court did not violate the Double Jeopardy Clause by increasing defendant's license suspension upon his ignition-interlock-device violation where defendant had not finished serving his original license suspension at the time of the violation.