State v. Yerkey

Citations

• 2024 Ohio 4849

Syllabus

Probation revocation proceedings must be initiated before expiration of community control sentence; state timely initiated probation revocation by filing a notification of hearing and violations and setting a show cause hearing two months before community control expired; court substantially complied with requirement to notify appellant of the right to retained counsel, Crim.R. 32.3(B); court failed to follow State v. Fugate by not applying jail time credit to all concurrent sentences; case remanded to apply 44 days of jail time credit to sentence.