State v. Griffon

Citations

• 2024 Ohio 5212

Syllabus

Community-control violations; due process; abuse of discretion; drug test; R.C. 2929.13(E)(2). The trial court abused its discretion in finding a violation of community-control sanctions because the violation was based on the defendant's alleged violation of protection orders that were not introduced into evidence for the purposes of determining whether his conduct constituted a violation, and a single instance of testing positive for drugs cannot form an independent basis of a violation of community-control sanctions unless the trial court makes the findings under R.C. 2929.13(E)(2) on the record.