State v. McQuade

Citations

• 2023 Ohio 1483

Syllabus

R.C. 2929.15 community-control conditions Jones test conceded error abuse of discretion. The trial court abused its discretion when it imposed community-control conditions prohibiting appellant from consuming drugs or alcohol, patronizing any location where drugs and/or alcohol are sold, served, or used including, but not limited to restaurants, bars, sporting venues, concerts, family weddings, backyard barbeques, private parties, political events, etc., and submitting to random testing. The record reflects that appellant did not have a history of drug or alcohol abuse, the conditions had no relationship to the crime, and the conditions did not serve the statutory ends of probation pursuant to the Jones test.