revocation sentencing hearing in Ohio

2019Montgomery No. 24998, 2012-Ohio-4615 (noting that the prison sentence for violating community control was not imposed until the revocation sentencing hearing, and that the trial court was required to comply with R.C. 2929.14(C)(4) to impose consecutive sentences). {¶ 20} The trial court provided the required notifications to Scott at his November 17, 2014 sentencing.

2015Montgomery No. 24998, 2012-Ohio-4615 (noting that the prison sentence for violating community control was not imposed until the revocation sentencing hearing, and that the trial court was required to comply with R.C. 2929.14(C)(4) to impose consecutive sentences); State v. Jacquillard, 1st Dist.

2023Champaign No. 2014-CA-34, 2015-Ohio-3789, ¶ 12 .

2019Champaign No. 2014-CA- 34, 2015-Ohio-3789, ¶ 12 , citing, e.g., State v. West, 2d Dist.

2018Butler No. CA2017-11-159, 2018-Ohio-3848, ¶ 29 , citing State v. Bates, 118 Ohio St.3d 174 , 2008–Ohio–1983, 887 N.E.2d 328, ¶ 19 . {¶14} The General Assembly has put some restraint on this “inherent authority” via the requirement of findings set forth in R.C. 2929.14(C)(4), and at least one Ohio appellate court has concluded that when an offender's community control is revoked and multiple prison terms are imposed, the trial court must make findings under R.C. 2929.14(C)(4) before imposing consecutive sentences at a revocation sentencing hearing.

2018Butler No. CA2017-11-159, 2018-Ohio-3848, ¶ 29 , citing State v. Bates, 118 Ohio St.3d 174 , 2008–Ohio–1983, 887 N.E.2d 328, ¶ 19 . {¶14} The General Assembly has put some restraint on this “inherent authority” via the requirement of findings set forth in R.C. 2929.14(C)(4), and at least one Ohio appellate court has concluded that when an offender's community control is revoked and multiple prison terms are imposed, the trial court must make findings under R.C. 2929.14(C)(4) before imposing consecutive sentences at a revocation sentencing hearing.

2018Butler No. CA2017-11-159, 2018-Ohio-3848, ¶ 29 , citing State v. Bates, 118 Ohio St.3d 174 , 2008–Ohio–1983, 887 N.E.2d 328, ¶ 19 . {¶14} The General Assembly has put some restraint on this “inherent authority” via the requirement of findings set forth in R.C. 2929.14(C)(4), and at least one Ohio appellate court has concluded that when an offender's community control is revoked and multiple prison terms are imposed, the trial court must make findings under R.C. 2929.14(C)(4) before imposing consecutive sentences at a revocation sentencing hearing.

2018Butler No. CA2017-11-159, 2018-Ohio-3848, ¶ 29 , citing State v. Bates, 118 Ohio St.3d 174 , 2008–Ohio–1983, 887 N.E.2d 328, ¶ 19 . {¶14} The General Assembly has put some restraint on this “inherent authority” via the requirement of findings set forth in R.C. 2929.14(C)(4), and at least one Ohio appellate court has concluded that when an offender's community control is revoked and multiple prison terms are imposed, the trial court must make findings under R.C. 2929.14(C)(4) before imposing consecutive sentences at a revocation sentencing hearing.

2015Hamilton No. C-140001, 2014-Ohio-4394 (applying R.C. 2929.14(C)(4) to sentencing upon revocation of community control); State v. Holman, 8th Dist.

2015Hamilton No. C-140001, 2014-Ohio-4394 (applying R.C. 2929.14(C)(4) to sentencing upon revocation of community control); State v. Holman, 8th Dist.

2023An appellate court must not reverse the denial of a continuance unless there has been an abuse of discretion.” State v. Unger, 67 Ohio St.2d 65, 67 , 423 N.E.2d 1078 (1981), citing Ungar v. Sarafite, 376 U.S. 575, 589 , 84 S.Ct. 841 , 11 L.Ed.2d 921 2 At the revocation sentencing hearing, appellee notified the court that the July 14, 2022 sentencing entry incorrectly identified the sentence as four years instead of five years and appellee noted that the court should issue a nunc pro tunc entry to accurately reflect the sentence.

2023An appellate court must not reverse the denial of a continuance unless there has been an abuse of discretion.” State v. Unger, 67 Ohio St.2d 65, 67 , 423 N.E.2d 1078 (1981), citing Ungar v. Sarafite, 376 U.S. 575, 589 , 84 S.Ct. 841 , 11 L.Ed.2d 921 2 At the revocation sentencing hearing, appellee notified the court that the July 14, 2022 sentencing entry incorrectly identified the sentence as four years instead of five years and appellee noted that the court should issue a nunc pro tunc entry to accurately reflect the sentence.

2023An appellate court must not reverse the denial of a continuance unless there has been an abuse of discretion.” State v. Unger, 67 Ohio St.2d 65, 67 , 423 N.E.2d 1078 (1981), citing Ungar v. Sarafite, 376 U.S. 575, 589 , 84 S.Ct. 841 , 11 L.Ed.2d 921 2 At the revocation sentencing hearing, appellee notified the court that the July 14, 2022 sentencing entry incorrectly identified the sentence as four years instead of five years and appellee noted that the court should issue a nunc pro tunc entry to accurately reflect the sentence.

2023An appellate court must not reverse the denial of a continuance unless there has been an abuse of discretion.” State v. Unger, 67 Ohio St.2d 65, 67 , 423 N.E.2d 1078 (1981), citing Ungar v. Sarafite, 376 U.S. 575, 589 , 84 S.Ct. 841 , 11 L.Ed.2d 921 2 At the revocation sentencing hearing, appellee notified the court that the July 14, 2022 sentencing entry incorrectly identified the sentence as four years instead of five years and appellee noted that the court should issue a nunc pro tunc entry to accurately reflect the sentence.

2015Athens No. 13CA8, 2014-Ohio-3733, ¶ 13 . {¶ 12} When an offender’s community control is revoked and multiple prison terms are imposed for the underlying offenses, the trial court must make the findings under R.C. 2929.14(C)(4) before imposing consecutive sentences at the revocation sentencing hearing.