post-release control violation (Ohio) · Go Syfert
← Ohio issues

post-release control violation in Ohio

89 Ohio opinions name it 2 courts 2000–2025 15 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
State v. Bloomergreen
ohio · 2009 · cited in 7 Ohio opinions naming this issue, 2011–2013
2 sentences

2011See also State v. Bloomer, 122 Ohio St.3d 200 , 2009-Ohio-2462 , 909 N.E.2d 1254, ¶ 70 (noting that a defendant cannot be subjected to another sentencing hearing after he “has completed the prison term imposed in his original sentence”); State v. Bezak, 114 Ohio St.3d 94 , 2007-Ohio-3250 , 868 N.E.2d 961, ¶ 18 (concluding that defendant could not be resentenced because he had “already served the prison term ordered by the trial court”). {¶ 24} In Bloomer , the Ohio Supreme Court further explained at ¶ 72: {¶ 25} “[T]he legislature has now amended R.C. 2929.14(F)(1) to provide: ‘If a court impo

2011See also State v. Bloomer, 122 Ohio St.3d 200 , 2009-Ohio-2462 , 909 N.E.2d 1254, ¶ 70 (noting that a defendant cannot be subjected to another sentencing hearing after he “has completed the prison term imposed in his original sentence”); State v. Bezak, 114 Ohio St.3d 94 , 2007-Ohio-3250 , 868 N.E.2d 961, ¶ 18 (concluding that defendant could not be resentenced because he had “already served the prison term ordered by the trial court”). {¶ 24} In Bloomer , the Ohio Supreme Court further explained at ¶ 72: {¶ 25} “[T]he legislature has now amended R.C. 2929.14(F)(1) to provide: ‘If a court impo

37
State v. Harrisgreen
ohioctapp · 2014 · cited in 4 Ohio opinions naming this issue, 2015–2025
2 sentences

2019Hamilton No. C-130442, 2014-Ohio-4237, ¶ 40 (defendant’s post-release control, which was not administratively revoked, did not terminate until the trial court imposed a prison term for the post-release control violation).

2018Hamilton No. C- 130442, 2014-Ohio-4237, ¶ 40 (defendant’s post-release control, which was not administratively revoked, did not terminate until the trial court imposed a prison term for the post-release control violation).

24
State v. Fischergreen
ohio · 2010 · cited in 10 Ohio opinions naming this issue, 2011–2017
2 sentences

2017Assignments of Error {¶ 8} Dixon assigns the following errors for our review: [1.] Did the Tenth District Court of appeal error when it Limited Appellant's re-sentencing to the Constraints of State v. Fischer, 128 Ohio St.3drd 92 2010-Ohio-6238 absent a Post Release Control violation. [2.] The trial court erred by imposing a imposition of PRC in this case, Appellant was not subject to any Post Release portion of Post release Control, the Imposition of Post Release Control should be reversed and remanded. [3.] The trial court erred when it denied Appellant opportunity to present his Newly disco

2017Assignments of Error {¶ 8} Dixon assigns the following errors for our review: [1.] Did the Tenth District Court of appeal error when it Limited Appellant's re-sentencing to the Constraints of State v. Fischer, 128 Ohio St.3drd 92 2010-Ohio-6238 absent a Post Release Control violation. [2.] The trial court erred by imposing a imposition of PRC in this case, Appellant was not subject to any Post Release portion of Post release Control, the Imposition of Post Release Control should be reversed and remanded. [3.] The trial court erred when it denied Appellant opportunity to present his Newly disco

110
State v. Singletonred
ohio · 2009 · cited in 6 Ohio opinions naming this issue, 2011–2014
2 sentences

2014Id. at ¶ 21 (nunc pro tunc entry can be used to reflect what actually took place where notification was properly given at sentencing hearing), comparing State v. Singleton, 124 Ohio St.3d 173 , 2009-Ohio-6434 , 920 N.E.2d 958, ¶ 4 (where the court failed to notify of the consequences of a post- release control violation at sentencing hearing). {¶16} In accordance, where the trial court does not advise the defendant at the sentencing hearing that the parole board can impose a prison term of up to one- half of his original sentence for a violation of post-release control, this court reverses and

2014Id. at ¶ 21 (nunc pro tunc entry can be used to reflect what actually took place where notification was properly given at sentencing hearing), comparing State v. Singleton, 124 Ohio St.3d 173 , 2009-Ohio-6434 , 920 N.E.2d 958, ¶ 4 (where the court failed to notify of the consequences of a post- release control violation at sentencing hearing). {¶16} In accordance, where the trial court does not advise the defendant at the sentencing hearing that the parole board can impose a prison term of up to one- half of his original sentence for a violation of post-release control, this court reverses and

16
State v. Martellogreen
ohio · 2002 · cited in 5 Ohio opinions naming this issue, 2003–2020
2 sentences

2020(Emphasis added). {¶14} It is evident that R.C. 2929.141 has explicitly taken into consideration the length of time the offender had served while on post-release control when it authorizes a trial court to impose the time remaining to be served on post-release control or twelve months, whichever is greater. {¶15} In State v. Martello, the Ohio Supreme Court held, R.C. 2967.28(F)(4), which specifies that a person released on post- release control who violates conditions of that post-release control faces a term of incarceration for the violation as well as criminal prosecution for the conduct t

2020(Emphasis added). {¶14} It is evident that R.C. 2929.141 has explicitly taken into consideration the length of time the offender had served while on post-release control when it authorizes a trial court to impose the time remaining to be served on post-release control or twelve months, whichever is greater. {¶15} In State v. Martello, the Ohio Supreme Court held, R.C. 2967.28(F)(4), which specifies that a person released on post- release control who violates conditions of that post-release control faces a term of incarceration for the violation as well as criminal prosecution for the conduct t

15
State v. Bishop (Slip Opinion)green
ohio · 2018 · cited in 4 Ohio opinions naming this issue, 2019–2023
2 sentences

2023The imposition of a prison term for the post-release control violation shall terminate the period of post-release control for the earlier felony. * * * {¶ 15} In State v. Bishop, 156 Ohio St.3d 156 , 2018-Ohio-5132 , 124 N.E.3d 766, ¶ 21 , the Supreme Court of Ohio held: Crim.R. 11(C)(2)(a) requires a trial court to advise a criminal defendant on post-release control for a prior felony, during his plea hearing in a new felony case, of the trial court’s authority under R.C. 2929.141 to terminate the defendant’s existing post-release control and to impose a consecutive prison sentence for the po

2023The imposition of a prison term for the post-release control violation shall terminate the period of post-release control for the earlier felony. * * * {¶ 15} In State v. Bishop, 156 Ohio St.3d 156 , 2018-Ohio-5132 , 124 N.E.3d 766, ¶ 21 , the Supreme Court of Ohio held: Crim.R. 11(C)(2)(a) requires a trial court to advise a criminal defendant on post-release control for a prior felony, during his plea hearing in a new felony case, of the trial court’s authority under R.C. 2929.141 to terminate the defendant’s existing post-release control and to impose a consecutive prison sentence for the po

14
State v. Martellogreen
ohio · 2002 · cited in 4 Ohio opinions naming this issue, 2003–2020
2 sentences

2020(Emphasis added). {¶14} It is evident that R.C. 2929.141 has explicitly taken into consideration the length of time the offender had served while on post-release control when it authorizes a trial court to impose the time remaining to be served on post-release control or twelve months, whichever is greater. {¶15} In State v. Martello, the Ohio Supreme Court held, R.C. 2967.28(F)(4), which specifies that a person released on post- release control who violates conditions of that post-release control faces a term of incarceration for the violation as well as criminal prosecution for the conduct t

2019Lake Nos. 2009-L-025, 2009-L-26, 2009-Ohio-6382 , ¶29, the court discussed the notification at the new felony sentencing and wrote “the General Assembly has indicated its clear intent that the prison term imposed for the violation of post-release control is a reinstatement of part of the original sentence for violating the conditions of supervision, and is not meant to be a separate criminal punishment.” Ervin, supra, at ¶ 31, citing State v. Martello, 97 Ohio St.3d 398 , 2002-Ohio-6661 , 780 N.E.2d 250, ¶ 19 .

14
State v. Bezakred
ohio · 2007 · cited in 2 Ohio opinions naming this issue, 2011–2011
2 sentences

2011See also State v. Bloomer, 122 Ohio St.3d 200 , 2009-Ohio-2462 , 909 N.E.2d 1254, ¶ 70 (noting that a defendant cannot be subjected to another sentencing hearing after he “has completed the prison term imposed in his original sentence”); State v. Bezak, 114 Ohio St.3d 94 , 2007-Ohio-3250 , 868 N.E.2d 961, ¶ 18 (concluding that defendant could not be resentenced because he had “already served the prison term ordered by the trial court”). {¶ 24} In Bloomer , the Ohio Supreme Court further explained at ¶ 72: {¶ 25} “[T]he legislature has now amended R.C. 2929.14(F)(1) to provide: ‘If a court impo

2011See also State v. Bloomer, 122 Ohio St.3d 200 , 2009-Ohio-2462 , 909 N.E.2d 1254, ¶ 70 (noting that a defendant cannot be subjected to another sentencing hearing after he “has completed the prison term imposed in his original sentence”); State v. Bezak, 114 Ohio St.3d 94 , 2007-Ohio-3250 , 868 N.E.2d 961, ¶ 18 (concluding that defendant could not be resentenced because he had “already served the prison term ordered by the trial court”). {¶ 24} In Bloomer , the Ohio Supreme Court further explained at ¶ 72: {¶ 25} “[T]he legislature has now amended R.C. 2929.14(F)(1) to provide: ‘If a court impo

12
State v. Eischengreen
ohioctapp · 2021 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Godsey argues that two other Ohio Appellate Districts have determined that R.C. 2929.141(A)(1) “does not authorize a trial court to terminate a postrelease control sanction upon the violation of a community control sanction.” State v. Eischen, 2021-Ohio-23, ¶ 16 (6th Dist.); State v. Prince, 2016-Ohio-2724, ¶ 23 (8th Dist.).

11
Cleveland Hts. v. Colemangreen
ohioctapp · 2021 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025E.g., Harris at ¶ 15 ; Cleveland Hts. v. Coleman, 2021-Ohio-846, ¶ 19-20 (8th Dist.); State v. Clark, 2008-Ohio-5208, ¶ 37 (12th Dist.); State v. Beverly, 2005-Ohio-4954 -10- (4th Dist.). {¶ 30} Nelson was arrested in this case on April 16, 2024, at Ross Correctional Institution, where he was serving time for a post-release control violation in another case.

11
State v. Clark, Ca2007-03-037 (10-6-2008)green
ohioctapp · 2008 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025E.g., Harris at ¶ 15 ; Cleveland Hts. v. Coleman, 2021-Ohio-846, ¶ 19-20 (8th Dist.); State v. Clark, 2008-Ohio-5208, ¶ 37 (12th Dist.); State v. Beverly, 2005-Ohio-4954 -10- (4th Dist.). {¶ 30} Nelson was arrested in this case on April 16, 2024, at Ross Correctional Institution, where he was serving time for a post-release control violation in another case.

11
State v. Princegreen
ohioctapp · 2016 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Godsey argues that two other Ohio Appellate Districts have determined that R.C. 2929.141(A)(1) “does not authorize a trial court to terminate a postrelease control sanction upon the violation of a community control sanction.” State v. Eischen, 2021-Ohio-23, ¶ 16 (6th Dist.); State v. Prince, 2016-Ohio-2724, ¶ 23 (8th Dist.).

11
State v. Cheekgreen
ohioctapp · 2022 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024The prison term for the post-release control violation “must be served consecutively to the prison term imposed on the new felony.” Id., citing R.C. 2929.141(A)(1). {¶ 13} We note that Monfort does not dispute that he was on post-release control when he committed his two drug possession offenses.

2024As previously discussed, under “R.C. 2929.141 * * * a defendant who commits a new felony offense while on [post-release control] can be ordered by the trial court that is imposing [a] sentence on the new felony offense to serve additional sanctions for violating [post- release control] including a prison term.” Cheek, 2022-Ohio-4736, at ¶ 11 (2d Dist.).

11
State v. Brewergreen
ohioctapp · 2014 · cited in 1 Ohio opinions naming this issue, 2017–2017
11
State v. Browngreen
ohioctapp · 2006 · cited in 1 Ohio opinions naming this issue, 2013–2013
11
State v. Kelley, Unpublished Decision (2-13-2006)green
ohioctapp · 2006 · cited in 1 Ohio opinions naming this issue, 2007–2007
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (50)

CaseCitedYears
State v. Qualls green
ohio · 2012
2 sentences

2018State v. Qualls, 131 Ohio St.3d 499 , 2012-Ohio-1111 , 967 N.E.2d 718 , ¶ 18-19. “[T]he sentencing entry must contain the following information: (1) whether postrelease control is discretionary or mandatory, (2) the duration of the postrelease-control period, and (3) a statement to the effect that the Adult Parole Authority (‘APA’) will administer the postrelease control pursuant to R.C. 2967.28 and that any violation by the offender of the conditions of postrelease control will subject the offender to the consequences set forth in that statute.” State v. Grimes, 151 Ohio St.3d 19 , 2017-Ohio-

2018State v. Qualls, 131 Ohio St.3d 499 , 2012-Ohio-1111 , 967 N.E.2d 718 , ¶ 18-19. “[T]he sentencing entry must contain the following information: (1) whether postrelease control is discretionary or mandatory, (2) the duration of the postrelease-control period, and (3) a statement to the effect that the Adult Parole Authority (‘APA’) will administer the postrelease control pursuant to R.C. 2967.28 and that any violation by the offender of the conditions of postrelease control will subject the offender to the consequences set forth in that statute.” State v. Grimes, 151 Ohio St.3d 19 , 2017-Ohio-

112013–2020
Woods v. Telb green
ohio · 2000
2 sentences

2003Woods v. Telb , 89 Ohio St.3d 504 , 2000-Ohio-171 , characterized post-release control as a "part of an offender's sentence." Id., at 513. {¶ 17} A court that imposes a sentence that includes post-release control must notify the offender of the post-release control requirement at sentencing, and that "if the offender violates that supervision or condition of post-release control . . . the parole board may impose a prison term, as a part of the sentence, of up to one-half of the stated prison term originally imposed on the offender." R.C. 2929.19 (B)(3)(e).

2003Woods v. Telb, 89 Ohio St.3d 504 , 2000-Ohio-171 , characterized post-release control as a "part of an offender's sentence." Id., at 513. {¶ 17} A court that imposes a sentence that includes post-release control must notify the offender of the post-release control requirement at sentencing, and that "if the offender violates that supervision or condition of post-release control . . . the parole board may impose a prison term, as a part of the sentence, of up to one-half of the stated prison term originally imposed on the offender." R.C. 2929.19 (B)(3)(e).

42000–2022
Anders v. California green
scotus · 1967
2 sentences

2017Following the court’s May 12, 2015 judgment entry, this consolidated appeal followed. {¶ 4} In counsel’s appellate brief, under procedures announced in Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967), counsel indicates that she has thoroughly examined the record, discussed the case with appellant, and is unable to find meritorious grounds for appeal.

2017Following the court’s May 12, 2015 judgment entry, this consolidated appeal followed. {¶ 4} In counsel’s appellate brief, under procedures announced in Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967), counsel indicates that she has thoroughly examined the record, discussed the case with appellant, and is unable to find meritorious grounds for appeal.

42008–2017
State v. Stiggers neutral
ohioctapp · 2011
2 sentences

2018Summit No. 25486, 2011-Ohio-4225, ¶ 6 , citing Fischer at ¶ 27–28. {¶8} Courts have recognized “that a trial court exceeds its sentencing authority when it conducts a[n entire] de novo [re]sentencing to correct a post- release control error * * * [b]ecause resentencing [under those circumstances] is limited to the imposition of post-release control, any additional action taken by the trial court with respect to the sentence is a nullity.” Stiggers at ¶ 7, citing State v. Cool, 9th Dist.

2012An appeal from the resentencing will be “limited to issues arising at the resentencing hearing.” Id. at paragraph four of the syllabus. “[W]here a trial court has erroneously conducted a de novo resentencing to remedy a post-release control error, this Court has excised the proper post-release control notification portion of the new sentencing entry and vacated the remainder of the entry.” State v. Wrenn, 9th Dist.

32011–2018
Woods v. Telb green
ohio · 2000
2 sentences

2003Woods v. Telb , 89 Ohio St.3d 504 , 2000-Ohio-171 , characterized post-release control as a "part of an offender's sentence." Id., at 513. {¶ 17} A court that imposes a sentence that includes post-release control must notify the offender of the post-release control requirement at sentencing, and that "if the offender violates that supervision or condition of post-release control . . . the parole board may impose a prison term, as a part of the sentence, of up to one-half of the stated prison term originally imposed on the offender." R.C. 2929.19 (B)(3)(e).

2003Woods v. Telb, 89 Ohio St.3d 504 , 2000-Ohio-171 , characterized post-release control as a "part of an offender's sentence." Id., at 513. {¶ 17} A court that imposes a sentence that includes post-release control must notify the offender of the post-release control requirement at sentencing, and that "if the offender violates that supervision or condition of post-release control . . . the parole board may impose a prison term, as a part of the sentence, of up to one-half of the stated prison term originally imposed on the offender." R.C. 2929.19 (B)(3)(e).

32000–2003
State v. Wells green
ohioctapp · 2015
2 sentences

2024ANALYSIS {¶49} In State v. Wells, 2015-Ohio-39 (5th Dist.), this Court addressed the same issue raised in the case sub judice.

2022Licking No. 14-CA-36, 2015-Ohio-39, ¶ 8 . {¶12} In other words, the trial court should have reached a total of 709 days for Mills’s maximum sentence for the post-release control violation without applying any jail-time credit.

22022–2024
State v. Grimes (Slip Opinion) green
ohio · 2017
2 sentences

2021Put another way, Chears contends that the trial court improperly told him at the plea hearing that he -12- Case No. 5-20-24 was potentially facing more prison time if he violated post-release control than he actually would have been subject to if he violated post-release control in the future. {¶26} In State v. Grimes, 151 Ohio St.3d 19 , 2017-Ohio-2927, ¶ 1 , the Supreme Court of Ohio defined what is required to impose post-release control, holding, that to validly impose postrelease control when the court orally provides all the required advisements at the sentencing hearing, the sentencing

2018State v. Qualls, 131 Ohio St.3d 499 , 2012-Ohio-1111 , 967 N.E.2d 718 , ¶ 18-19. “[T]he sentencing entry must contain the following information: (1) whether postrelease control is discretionary or mandatory, (2) the duration of the postrelease-control period, and (3) a statement to the effect that the Adult Parole Authority (‘APA’) will administer the postrelease control pursuant to R.C. 2967.28 and that any violation by the offender of the conditions of postrelease control will subject the offender to the consequences set forth in that statute.” State v. Grimes, 151 Ohio St.3d 19 , 2017-Ohio-

22018–2021
State v. Sarkozy green
ohio · 2008
2 sentences

2020Bishop at ¶ 19 , quoting Clark at ¶ 32, quoting State v. Sarkozy, 117 Ohio St.3d 86 , 2008-Ohio-509 , 881 N.E.2d 1224, ¶ 22 . {¶ 8} Turning then to the maximum penalty advisement that is required when a defendant is on PRC, R.C. 2929.141(A)(1) provides the following: -6- (A) Upon the conviction of or plea of guilty to a felony by a person on post- release control at the time of the commission of the felony, the court may terminate the term of post-release control, and the court may do either of the following regardless of whether the sentencing court or another court of this state imposed the

2020Bishop at ¶ 19 , quoting Clark at ¶ 32, quoting State v. Sarkozy, 117 Ohio St.3d 86 , 2008-Ohio-509 , 881 N.E.2d 1224, ¶ 22 . {¶ 8} Turning then to the maximum penalty advisement that is required when a defendant is on PRC, R.C. 2929.141(A)(1) provides the following: -6- (A) Upon the conviction of or plea of guilty to a felony by a person on post- release control at the time of the commission of the felony, the court may terminate the term of post-release control, and the court may do either of the following regardless of whether the sentencing court or another court of this state imposed the

22011–2020
State v. Crangle green
ohioctapp · 2011
2 sentences

2019Id.

2018Id.

22018–2019
State v. Branham neutral
ohioctapp · 2014
2 sentences

2017Clark No. 2013 CA 49, 2014-Ohio-5067 , and State v. Landgraf, 2d Dist.

2017Clark No. 2013 CA 49, 2014-Ohio-5067 , this court addressed a similar issue.

22017–2017
Strickland v. Washington green
scotus · 1984
2 sentences

2003No. C-000533. 4 See Sheppard , supra. 5 See Strickland v. Washington (1984), 466 U.S. 668 , 687 , 104 S.Ct. 2052 . 6 The record does not include the transcript of the plea and sentencing hearings in the sexual-battery case. 7 Specifically, the court cited Edwards's post-release-control status in finding that he posed the "greatest likelihood of recidivism" under R.C. 2929.14 (C). 8 The Supreme Court of Ohio has held that there is no double jeopardy violation where a trial court imposes imprisonment for a post-release-control violation and for the offense that was the subject of the violation.

2003No. C-000533. 4 See Sheppard , supra. 5 See Strickland v. Washington (1984), 466 U.S. 668 , 687 , 104 S.Ct. 2052 . 6 The record does not include the transcript of the plea and sentencing hearings in the sexual-battery case. 7 Specifically, the court cited Edwards's post-release-control status in finding that he posed the "greatest likelihood of recidivism" under R.C. 2929.14 (C). 8 The Supreme Court of Ohio has held that there is no double jeopardy violation where a trial court imposes imprisonment for a post-release-control violation and for the offense that was the subject of the violation.

22003–2006
State v. Carroll green
ohioctapp · 1995
2 sentences

2003State v. Carroll (1995), 104 Ohio App.3d 372 . {¶ 26} R.C. 2929.14 (F) provides that a post-release control requirement is a part of an offender's "sentence," a point confirmed by Woods v. Telb .

2003State v. Carroll (1995), 104 Ohio App.3d 372 . {¶ 26} R.C. 2929.14 (F) provides that a post-release control requirement is a part of an offender's "sentence," a point confirmed by Woods v. Telb.

22003–2003
Goldberg v. Kelly green
scotus · 1970
2 sentences

2000In Goldberg v. Kelly (1970), 397 U.S. 254 , the United States Supreme Court concluded that "the fundamental requisite of due process of law is the opportunity to be heard in a meaningful time and in a meaningful manner." Woods, supra , at __.

2000We conclude that these protections provided in the Ohio Administrative Code not only comport with those required by Morrissey v. Brewer, but go beyond Morrissey by guaranteeing the right to counsel as well. {¶ 39} In Goldberg v. Kelly (1970), 397 U.S. 254 , 90 S.Ct. 1011 , 25 L.Ed.2d 287 , the United States Supreme Court considered what process was due in the revocation of public assistance benefits.

22000–2000
State v. Beverly, Unpublished Decision (9-13-2005) green
ohioctapp · 2005
1 sentence

2025E.g., Harris at ¶ 15 ; Cleveland Hts. v. Coleman, 2021-Ohio-846, ¶ 19-20 (8th Dist.); State v. Clark, 2008-Ohio-5208, ¶ 37 (12th Dist.); State v. Beverly, 2005-Ohio-4954 -10- (4th Dist.). {¶ 30} Nelson was arrested in this case on April 16, 2024, at Ross Correctional Institution, where he was serving time for a post-release control violation in another case.

12025–2025
State v. Nero green
ohio · 1990
1 sentence

2025“The test for prejudice is ‘whether the plea would have otherwise been made.’ ” Dangler, 2020-Ohio-2765, at ¶ 16 , quoting Nero, 56 Ohio St.3d at 108 . {¶ 13} In this case, Smith failed to point to anything in the record indicating that he would not have entered his guilty plea to domestic violence but for the post-release- control error in the plea form.

12025–2025
State v. Dangler (Slip Opinion) green
· 2020
1 sentence

2025“The test for prejudice is ‘whether the plea would have otherwise been made.’ ” Dangler, 2020-Ohio-2765, at ¶ 16 , quoting Nero, 56 Ohio St.3d at 108 . {¶ 13} In this case, Smith failed to point to anything in the record indicating that he would not have entered his guilty plea to domestic violence but for the post-release- control error in the plea form.

12025–2025
State v. McIntosh green
ohioctapp · 2023
1 sentence

2024McIntosh, 2023-Ohio-4022, at ¶ 65 . {¶ 102} Furthermore, unlike post-release control, the Reagan Tokes notifications do not apply to every prison sentence, and the statutory scheme does not allow the DRC to restrain a defendant’s liberty after serving his or her sentence like a post-release control violation could.

12024–2024
State v. Krouskoupf neutral
ohioctapp · 2019
12022–2022
State v. Fultz neutral
ohioctapp · 2019
12022–2022
State v. Lincoln neutral
ohioctapp · 2019
12021–2021
State Ex Rel. Jordan v. Haskins neutral
ohioctapp · 1998
12021–2021
State v. Flanagan neutral
ohioctapp · 2012
12020–2020
United States v. Brown green
scotus · 1965
12019–2019
Nixon v. Administrator of General Services green
scotus · 1977
12019–2019
State v. Figueroa neutral
ohioctapp · 2016
12019–2019
v. Department of Corrections green
coloctapp · 2019
12019–2019
State v. Clark green
ohio · 2008
12019–2019
State v. Anderson neutral
ohioctapp · 2018
12018–2018
State v. Dunwoody neutral
ohioctapp · 2018
12018–2018
State v. Belton neutral
ohio · 2017
12018–2018
State v. Rice green
ohioctapp · 2016
12018–2018
State ex rel. Carnail v. McCormick green
ohio · 2010
12018–2018
State v. Harkins green
ohioctapp · 2012
12018–2018
State v. Cool neutral
ohioctapp · 2011
12018–2018
State v. Welch green
ohioctapp · 2017
12017–2017
State v. Billiter green
ohio · 2012
12016–2016
State v. Dowey neutral
ohioctapp · 2012
12016–2016
State v. Wooden neutral
ohioctapp · 2011
12016–2016
State ex rel. Gregley v. Friedman (Slip Opinion) neutral
ohio · 2014
12015–2015
State v. Hach neutral
ohioctapp · 2014
12014–2014

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2967.28 (37) OH § Ohio Rev. Code § 2929.141 (31) OH § Ohio Rev. Code § 2929.19 (27) OH § Ohio Rev. Code § 2929.14 (18) OH § Ohio Rev. Code § 2929.191 (11) OH § Ohio Rev. Code § 2953.08 (11) OH § Ohio Rev. Code § 2929.12 (8) OH § Ohio Rev. Code § 2947.23 (8) OH § Ohio Rev. Code § 2903.11 (7) OH § Ohio Rev. Code § 2929.11 (7) OH § Ohio Rev. Code § 2967.01 (7) OH § Ohio Rev. Code § 2907.02 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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