State v. Patrick

Citations

• 2022 Ohio 4171

Syllabus

NO-CONTACT ORDER – COMMUNITY CONTROL — NOTIFICIATION OF POSTRELEASE CONTROL – R.C. 2929.191: The trial court erred in imposing both a prison term and a community control sanction (a no-contact order) for the same offense. The trial court's recommendation that defendant complete mental health treatment and substance-abuse counseling while incarcerated was not a community-control sanction, but merely a recommendation. The trial court failed to properly advise defendant of the terms of his postrelease control at the sentencing hearing nevertheless, the court may correct this error by following the procedure set forth in R.C. 2929.191.