Ohio Revised Code

Ohio Rev. Code § 2929.15 (2026)

Community control sanctions; felony

✓ current as of May 2026
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(A)(1) If in sentencing an offender for a felony the court is not required to impose a prison term, a mandatory prison term, or a term of life imprisonment upon the offender, the court may directly impose a sentence that consists of one or more community control sanctions authorized pursuant to section 2929.16, 2929.17, or 2929.18 of the Revised Code. If the court is sentencing an offender for a fourth degree felony OVI offense under division (G)(1) of section 2929.13 of the Revised Code, in addition to the mandatory term of local incarceration imposed under that division and the mandatory fine required by division (B)(3) of section 2929.18 of the Revised Code, the court may impose upon the offender a community control sanction or combination of community control sanctions in accordance with sections 2929.16 and 2929.17 of the Revised Code. If the court is sentencing an offender for a third or fourth degree felony OVI offense under division (G)(2) of section 2929.13 of the Revised Code, in addition to the mandatory prison term or mandatory prison term and additional prison term imposed under that division, the court also may impose upon the offender a community control sanction or combination of community control sanctions under section 2929.16 or 2929.17 of the Revised Code, but the offender shall serve all of the prison terms so imposed prior to serving the community control sanction.

The duration of all community control sanctions imposed on an offender under this division shall not exceed five years. If the offender absconds or otherwise leaves the jurisdiction of the court in which the offender resides without obtaining permission from the court or the offender's probation officer to leave the jurisdiction of the court, or if the offender is confined in any institution for the commission of any offense while under a community control sanction, the period of the community control sanction ceases to run until the offender is brought before the court for its further action. If the court sentences the offender to one or more nonresidential sanctions under section 2929.17 of the Revised Code, the court shall impose as a condition of the nonresidential sanctions that, during the period of the sanctions, the offender must abide by the law and must not leave the state without the permission of the court or the offender's probation officer. The court may impose any other conditions of release under a community control sanction that the court considers appropriate, including, but not limited to, requiring that the offender not ingest or be injected with a drug of abuse and submit to random drug testing as provided in division (D) of this section to determine whether the offender ingested or was injected with a drug of abuse and requiring that the results of the drug test indicate that the offender did not ingest or was not injected with a drug of abuse.

(2)(a) If a court sentences an offender to any community control sanction or combination of community control sanctions authorized pursuant to section 2929.16, 2929.17, or 2929.18 of the Revised Code, the court shall place the offender under the general control and supervision of a department of probation in the county that serves the court for purposes of reporting to the court a violation of any condition of the sanctions, any condition of release under a community control sanction imposed by the court, a violation of law, or the departure of the offender from this state without the permission of the court or the offender's probation officer. Alternatively, if the offender resides in another county and a county department of probation has been established in that county or that county is served by a multicounty probation department established under section 2301.27 of the Revised Code, the court may request the court of common pleas of that county to receive the offender into the general control and supervision of that county or multicounty department of probation for purposes of reporting to the court a violation of any condition of the sanctions, any condition of release under a community control sanction imposed by the court, a violation of law, or the departure of the offender from this state without the permission of the court or the offender's probation officer, subject to the jurisdiction of the trial judge over and with respect to the person of the offender, and to the rules governing that department of probation.

If there is no department of probation in the county that serves the court, the court shall place the offender, regardless of the offender's county of residence, under the general control and supervision of the adult parole authority, unless the court has entered into an agreement with the authority as described in division (B) or (C) of section 2301.32 of the Revised Code, or under an entity authorized under division (B) of section 2301.27 of the Revised Code to provide probation and supervisory services to counties for purposes of reporting to the court a violation of any of the sanctions, any condition of release under a community control sanction imposed by the court, a violation of law, or the departure of the offender from this state without the permission of the court or the offender's probation officer.

(b) If the court imposing sentence on an offender sentences the offender to any community control sanction or combination of community control sanctions authorized pursuant to section 2929.16, 2929.17, or 2929.18 of the Revised Code, and if the offender violates any condition of the sanctions, violates any condition of release under a community control sanction imposed by the court, violates any law, or departs the state without the permission of the court or the offender's probation officer, the public or private person or entity that operates or administers the sanction or the program or activity that comprises the sanction shall report the violation or departure directly to the sentencing court, or shall report the violation or departure to the county or multicounty department of probation with general control and supervision over the offender under division (A)(2)(a) of this section or the officer of that department who supervises the offender, or, if there is no such department with general control and supervision over the offender under that division, to the adult parole authority unless the court has entered into an agreement with the authority as described in division (B) or (C) of section 2301.32 of the Revised Code, or to an entity authorized under division (B) of section 2301.27 of the Revised Code to provide probation and supervisory services to the county. If the public or private person or entity that operates or administers the sanction or the program or activity that comprises the sanction reports the violation or departure to the county or multicounty department of probation, the adult parole authority, or any other entity providing probation and supervisory services to the county, the department's, authority's, or other entity's officers may treat the offender as if the offender were on probation and in violation of the probation, and shall report the violation of the condition of the sanction, any condition of release under a community control sanction imposed by the court, the violation of law, or the departure from the state without the required permission to the sentencing court.

(3) If an offender who is eligible for community control sanctions under this section admits to having a drug addiction or the court has reason to believe that the offender has a drug addiction, and if the offense for which the offender is being sentenced was related to the addiction, the court may require that the offender be assessed by a properly credentialed professional within a specified period of time and shall require the professional to file a written assessment of the offender with the court. If a court imposes treatment and recovery support services as a community control sanction, the court shall direct the level and type of treatment and recovery support services after consideration of the written assessment, if available at the time of sentencing, and recommendations of the professional and other treatment and recovery support services providers.

(4) If an assessment completed pursuant to division (A)(3) of this section indicates that the offender has an addiction to drugs or alcohol, the court may include in any community control sanction imposed for a violation of section 2925.02, 2925.03, 2925.04, 2925.05, 2925.06, 2925.11, 2925.13, 2925.22, 2925.23, 2925.36, or 2925.37 of the Revised Code a requirement that the offender participate in alcohol and drug addiction services and recovery supports certified under section 5119.36 of the Revised Code or offered by a properly credentialed community addiction services provider.

(B)(1) Except as provided in division (B)(2) of this section, if the conditions of a community control sanction imposed for a felony are violated or if the offender violates a law or leaves the state without the permission of the court or the offender's probation officer, the sentencing court may impose on the violator one or more of the following penalties:

(a) A longer time under the same sanction if the total time under the sanctions does not exceed the five-year limit specified in division (A) of this section;

(b) A more restrictive sanction under section 2929.16, 2929.17, or 2929.18 of the Revised Code, including but not limited to, a new term in a community-based correctional facility, halfway house, or jail pursuant to division (A)(6) of section 2929.16 of the Revised Code;

(c) A prison term on the offender pursuant to section 2929.14 of the Revised Code and division (B)(3) of this section, provided that a prison term imposed under this division is subject to the following limitations and rules, as applicable:

(i) If the prison term is imposed for any technical violation of the conditions of a community control sanction imposed for a felony of the fifth degree, the prison term shall not exceed ninety days, provided that if the remaining period of community control at the time of the violation or the remaining period of the reserved prison sentence at that time is less than ninety days, the prison term shall not exceed the length of the remaining period of community control or the remaining period of the reserved prison sentence. If the court imposes a prison term as described in this division, division (B)(2)(b) of this section applies.

(ii) If the prison term is imposed for any technical violation of the conditions of a community control sanction imposed for a felony of the fourth degree that is not an offense of violence and is not a sexually oriented offense, the prison term shall not exceed one hundred eighty days, provided that if the remaining period of the community control at the time of the violation or the remaining period of the reserved prison sentence at that time is less than one hundred eighty days, the prison term shall not exceed the length of the remaining period of community control or the remaining period of the reserved prison sentence. If the court imposes a prison term as described in this division, division (B)(2)(b) of this section applies.

(iii) A court is not limited in the number of times it may sentence an offender to a prison term under division (B)(1)(c) of this section for a violation of the conditions of a community control sanction or for a violation of a law or leaving the state without the permission of the court or the offender's probation officer. If an offender who is under a community control sanction violates the conditions of the sanction or violates a law or leaves the state without the permission of the court or the offender's probation officer, is sentenced to a prison term for the violation or conduct, is released from the term after serving it, and subsequently violates the conditions of the sanction or violates a law or leaves the state without the permission of the court or the offender's probation officer, the court may impose a new prison term sanction on the offender under division (B)(1)(c) of this section for the subsequent violation or conduct.

(2)(a) If an offender was acting pursuant to division (B)(2)(b) of section 2925.11 or a related provision of section 2925.12, 2925.14, or 2925.141 of the Revised Code and in so doing violated the conditions of a community control sanction based on a minor drug possession offense, as defined in section 2925.11 of the Revised Code, or violated section 2925.12, division (C)(1) of section 2925.14, or section 2925.141 of the Revised Code, the sentencing court shall not impose any of the penalties described in division (B)(1) of this section based on the violation.

(b) If a court imposes a prison term on an offender under division (B)(1)(c)(i) or (ii) of this section for a technical violation of the conditions of a community control sanction, one of the following is applicable with respect to the time that the offender spends in prison under the term:

(i) Subject to division (B)(2)(b)(ii) of this section, it shall be credited against the offender's community control sanction that was being served at the time of the violation, and the remaining time under that community control sanction shall be reduced by the time that the offender spends in prison under the prison term. By determination of the court, the offender upon release from the prison term either shall continue serving the remaining time under the community control sanction, as reduced under this division, or shall have the community control sanction terminated.

(ii) If, at the time a prison term is imposed for a technical violation, the offender was serving a residential community control sanction imposed under section 2929.16 of the Revised Code, the time spent serving the residential community control sanction shall be credited against the offender's reserved prison sentence, and the remaining time under that residential community control sanction and under the reserved prison sentence shall be reduced by the time that the offender spends in prison under the prison term. By determination of the court, the offender upon release from the prison term either shall continue serving the remaining time under the residential community control sanction, as reduced under this division, or shall have the residential community control sanction terminated.

(3) The prison term, if any, imposed on a violator pursuant to this division and division (B)(1) of this section shall be within the range of prison terms described in this division and shall not exceed a prison term from the range of terms specified in the notice provided to the offender at the sentencing hearing pursuant to division (B)(4) of section 2929.19 of the Revised Code. The court may reduce the longer period of time that the offender is required to spend under the longer sanction, the more restrictive sanction, or a prison term imposed pursuant to division (B)(1) of this section by the time the offender successfully spent under the sanction that was initially imposed. Except as otherwise specified in this division, the prison term imposed under this division and division (B)(1) of this section shall be within the range of prison terms available as a definite term for the offense for which the sanction that was violated was imposed. If the offense for which the sanction that was violated was imposed is a felony of the first or second degree committed on or after March 22, 2019, the prison term so imposed under this division shall be within the range of prison terms available as a minimum term for the offense under division (A)(1)(a) or (2)(a) of section 2929.14 of the Revised Code.

(C) If an offender, for a significant period of time, fulfills the conditions of a sanction imposed pursuant to section 2929.16, 2929.17, or 2929.18 of the Revised Code in an exemplary manner, the court may reduce the period of time under the sanction or impose a less restrictive sanction, but the court shall not permit the offender to violate any law or permit the offender to leave the state without the permission of the court or the offender's probation officer.

(D)(1) If a court under division (A)(1) of this section imposes a condition of release under a community control sanction that requires the offender to submit to random drug testing, the department of probation, the adult parole authority, or any other entity that has general control and supervision of the offender under division (A)(2)(a) of this section may cause the offender to submit to random drug testing performed by a laboratory or entity that has entered into a contract with any of the governmental entities or officers authorized to enter into a contract with that laboratory or entity under section 341.26, 753.33, or 5120.63 of the Revised Code.

(2) If no laboratory or entity described in division (D)(1) of this section has entered into a contract as specified in that division, the department of probation, the adult parole authority, or any other entity that has general control and supervision of the offender under division (A)(2)(a) of this section shall cause the offender to submit to random drug testing performed by a reputable public laboratory to determine whether the individual who is the subject of the drug test ingested or was injected with a drug of abuse.

(3) A laboratory or entity that has entered into a contract pursuant to section 341.26, 753.33, or 5120.63 of the Revised Code shall perform the random drug tests under division (D)(1) of this section in accordance with the applicable standards that are included in the terms of that contract. A public laboratory shall perform the random drug tests under division (D)(2) of this section in accordance with the standards set forth in the policies and procedures established by the department of rehabilitation and correction pursuant to section 5120.63 of the Revised Code. An offender who is required under division (A)(1) of this section to submit to random drug testing as a condition of release under a community control sanction and whose test results indicate that the offender ingested or was injected with a drug of abuse shall pay the fee for the drug test if the department of probation, the adult parole authority, or any other entity that has general control and supervision of the offender requires payment of a fee. A laboratory or entity that performs the random drug testing on an offender under division (D)(1) or (2) of this section shall transmit the results of the drug test to the appropriate department of probation, the adult parole authority, or any other entity that has general control and supervision of the offender under division (A)(2)(a) of this section.

(E) As used in this section, "technical violation" means a violation of the conditions of a community control sanction imposed for a felony of the fifth degree, or for a felony of the fourth degree that is not an offense of violence and is not a sexually oriented offense, and to which neither of the following applies:

(1) The violation consists of a new criminal offense that is a felony or that is a misdemeanor other than a minor misdemeanor, and the violation is committed while under the community control sanction.

(2) The violation consists of or includes the offender's articulated or demonstrated refusal to participate in the community control sanction imposed on the offender or any of its conditions, and the refusal demonstrates to the court that the offender has abandoned the objects of the community control sanction or condition.

The Legislative Service Commission presents the text of this section as a composite of the section as amended by multiple acts of the General Assembly. This presentation recognizes the principle stated in R.C. 1.52(B) that amendments are to be harmonized if reasonably capable of simultaneous operation.

Last updated February 13, 2023 at 3:37 PM

Notes of Decisions
Cited in 647 cases (225 in the last 5 years), 1985–2026 · leading case: State v. Nelson (Slip Opinion), 2020 Ohio 3690 (Ohio 2020).
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State v. Nelson (Slip Opinion), 2020 Ohio 3690 (Ohio 2020). · cites it 70× “{¶ 20} We also find that the interpretation of the term “technical violation” in Davis and Mannah makes sense when R.C. 2929.15 is viewed as a whole and that Nelson’s interpretation—that “technical violation” means any noncriminal violation—does not.”
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). · cites it 51× “15(C) so as to automatically lessen the offender’s sanction. Any adjustment in the terms of community control requires court action.”
State v. Brooks, 814 N.E.2d 837 (Ohio 2004). · cites it 18× “19(B)(5) {¶ 4} The issue certified for our review is “[Wjhether or not R.C. 2929.15[B], second sentence, read in pari materia with R.”
State v. Fraley, 2004 Ohio 7110 (Ohio 2004). · cites it 22× “” {¶ 10} R.C. 2929.15(B), which details procedures for a trial court to follow when an offender has violated the conditions of community control, reiterates the three options available to the sentencing court mentioned in R.”
State v. Calhoun, 2019 Ohio 228 (Ohio Ct. App. 2019). · cites it 27× “{¶ 3} At that time, R.C. 2929.15(A)(1) stated: If in sentencing an offender for a felony the court is not required to impose a prison term, a mandatory prison term, or a term of life imprisonment upon the offender, the court may directly impose a sentence that consists of one or…”
State v. Neville, 2019 Ohio 151 (Ohio Ct. App. 2019). · cites it 29× “She raises one assignment of error for our review: The trial court's twelve-month prison sentence for a technical violation of community control sanctions is contrary to law because it exceeded the 90-day maximum sentence authorized by R.C. 2929.15. {¶3} Finding no merit to her…”
State v. Hitchcock (Slip Opinion), 2019 Ohio 3246 (Ohio 2019). · cites it 12× “14 or community-control sanctions under R.C. 2929.15. In making this determination, the trial court is sometimes guided by statutory presumptions or preferences affixed to certain felony levels.”
State v. Anderson, 2016 Ohio 7044 (Ohio Ct. App. 2016). · cites it 15× “102428, 2015-Ohio-4581, at ¶ 13 (R.C. 2929.15 authorizes the trial court to generally impose a combination of community control sanctions on a single felony count).”
State v. Davis, 2018 Ohio 2672 (Ohio Ct. App. 2018). · cites it 13× “-5- Warren CA2017-11-156 {¶ 16} The appellate court observed that while "technical violation" was not defined in R.C. 2929.15, other appellate districts had addressed "technical violations" as they pertained to revocation of community control sanctions and parole violations in…”
State v. Cozzone, 2018 Ohio 2249 (Ohio Ct. App. 2018). · cites it 12× “The trial court further invited the parties to submit, after the sentence was journalized, written arguments addressing whether the amendments to R.C. 2929.15 were applicable to appellant's case.”
State v. Jenkins, 2011 Ohio 6924 (Ohio Ct. App. 2011). · cites it 28× “For example, the Third Appellate District stated that “the rules dealing with a violation of an original sentence of community control (R.C. 2929.15) should not be confused with the sections of the Revised Code regarding early judicial release (R.”
State v. Howard (Slip Opinion), 2020 Ohio 3195 (Ohio 2020). · cites it 11× “] Sentencing—Community control—Consecutive sentences—R.C. 2929.15(B)—R.C. 2929.19(B)—R.C. 2929.”
Show all 647 citing cases →
— Ohio Rev. Code § 2929.15(3)(b) — 1 case
State v. Jones, 2020 Ohio 762 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2929.15(8) — 1 case
Ellis v. Gray (S.D. Ohio 2022).
— Ohio Rev. Code § 2929.15(A) — 33 cases
State v. Hitchcock (Slip Opinion), 2019 Ohio 3246 (Ohio 2019). “14 or community-control sanctions under R.C. 2929.15. In making this determination, the trial court is sometimes guided by statutory presumptions or preferences affixed to certain felony levels.”
State v. Mize, 2018 Ohio 3848 (Ohio Ct. App. 2018).
State v. Vlad, 790 N.E.2d 1246 (Ohio Ct. App. 2003).
State v. LaSalla, 2013 Ohio 4596 (Ohio Ct. App. 2013).
State v. Ridley, 2022 Ohio 2561 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2929.15(A)(1) — 145 cases
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). “15(C) so as to automatically lessen the offender’s sanction. Any adjustment in the terms of community control requires court action.”
State v. Anderson, 2016 Ohio 7044 (Ohio Ct. App. 2016). “102428, 2015-Ohio-4581, at ¶ 13 (R.C. 2929.15 authorizes the trial court to generally impose a combination of community control sanctions on a single felony count).”
State v. Jenkins, 2011 Ohio 6924 (Ohio Ct. App. 2011). “For example, the Third Appellate District stated that “the rules dealing with a violation of an original sentence of community control (R.C. 2929.15) should not be confused with the sections of the Revised Code regarding early judicial release (R.”
State v. Aguirre (Slip Opinion), 2014 Ohio 4603 (Ohio 2014).
State v. Hitchcock (Slip Opinion), 2019 Ohio 3246 (Ohio 2019). “14 or community-control sanctions under R.C. 2929.15. In making this determination, the trial court is sometimes guided by statutory presumptions or preferences affixed to certain felony levels.”
— Ohio Rev. Code § 2929.15(A)(1)(a) — 2 cases
Walton Hills v. Olesinski, 2020 Ohio 5618 (Ohio Ct. App. 2020).
State v. Hootman, 2019 Ohio 607 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2929.15(A)(2) — 4 cases
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). “15(C) so as to automatically lessen the offender’s sanction. Any adjustment in the terms of community control requires court action.”
State v. Paxton, 742 N.E.2d 1171 (Ohio Ct. App. 2000).
State v. Nash, 2012 Ohio 3246 (Ohio Ct. App. 2012).
State v. Hunt, 2012 Ohio 3578 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2929.15(A)(2)(a) — 13 cases
State v. Heinz (Slip Opinion), 2016 Ohio 2814 (Ohio 2016).
State v. Hitchcock (Slip Opinion), 2019 Ohio 3246 (Ohio 2019). “14 or community-control sanctions under R.C. 2929.15. In making this determination, the trial court is sometimes guided by statutory presumptions or preferences affixed to certain felony levels.”
State v. Amos (Slip Opinion), 2014 Ohio 3160 (Ohio 2014).
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). “15(C) so as to automatically lessen the offender’s sanction. Any adjustment in the terms of community control requires court action.”
State v. Young, 798 N.E.2d 629 (Ohio Ct. App. 2003).
— Ohio Rev. Code § 2929.15(A)(2)(b) — 7 cases
State v. Heinz (Slip Opinion), 2016 Ohio 2814 (Ohio 2016).
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). “15(C) so as to automatically lessen the offender’s sanction. Any adjustment in the terms of community control requires court action.”
State ex rel. Hemsley v. Burnham Unruh, 2011 Ohio 226 (Ohio 2011).
State v. Washington, 2015 Ohio 305 (Ohio Ct. App. 2015).
State v. Dawson, 2018 Ohio 2685 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2929.15(A)(3) — 2 cases
State v. Newsome, 2013 Ohio 4587 (Ohio Ct. App. 2013).
State v. Boggs, 2026 Ohio 1472 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2929.15(A)(3)(a) — 1 case
State v. Briskey, 2012 Ohio 5340 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2929.15(A)(3)(c) — 1 case
State v. Coffer, 2020 Ohio 994 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2929.15(A)(5) — 1 case
State v. Brown, 737 N.E.2d 1057 (Ohio Ct. App. 2000).
— Ohio Rev. Code § 2929.15(B) — 210 cases
State v. Fraley, 2004 Ohio 7110 (Ohio 2004). “” {¶ 10} R.C. 2929.15(B), which details procedures for a trial court to follow when an offender has violated the conditions of community control, reiterates the three options available to the sentencing court mentioned in R.”
State v. Brooks, 814 N.E.2d 837 (Ohio 2004). “19(B)(5) {¶ 4} The issue certified for our review is “[Wjhether or not R.C. 2929.15[B], second sentence, read in pari materia with R.”
State v. Davis, 2018 Ohio 2672 (Ohio Ct. App. 2018). “-5- Warren CA2017-11-156 {¶ 16} The appellate court observed that while "technical violation" was not defined in R.C. 2929.15, other appellate districts had addressed "technical violations" as they pertained to revocation of community control sanctions and parole violations in…”
State v. Calhoun, 2019 Ohio 228 (Ohio Ct. App. 2019). “{¶ 3} At that time, R.C. 2929.15(A)(1) stated: If in sentencing an offender for a felony the court is not required to impose a prison term, a mandatory prison term, or a term of life imprisonment upon the offender, the court may directly impose a sentence that consists of one or…”
State v. Cozzone, 2018 Ohio 2249 (Ohio Ct. App. 2018). “The trial court further invited the parties to submit, after the sentence was journalized, written arguments addressing whether the amendments to R.C. 2929.15 were applicable to appellant's case.”
— Ohio Rev. Code § 2929.15(B)(1) — 83 cases
State v. Nelson (Slip Opinion), 2020 Ohio 3690 (Ohio 2020). “{¶ 20} We also find that the interpretation of the term “technical violation” in Davis and Mannah makes sense when R.C. 2929.15 is viewed as a whole and that Nelson’s interpretation—that “technical violation” means any noncriminal violation—does not.”
State v. Neville, 2019 Ohio 151 (Ohio Ct. App. 2019). “She raises one assignment of error for our review: The trial court's twelve-month prison sentence for a technical violation of community control sanctions is contrary to law because it exceeded the 90-day maximum sentence authorized by R.C. 2929.15. {¶3} Finding no merit to her…”
State v. Heinz (Slip Opinion), 2016 Ohio 2814 (Ohio 2016).
State v. Morris, 2016 Ohio 7614 (Ohio Ct. App. 2016).
State v. Cozzone, 2018 Ohio 2249 (Ohio Ct. App. 2018). “The trial court further invited the parties to submit, after the sentence was journalized, written arguments addressing whether the amendments to R.C. 2929.15 were applicable to appellant's case.”
— Ohio Rev. Code § 2929.15(B)(1)(C) — 1 case
State v. Urban, 2019 Ohio 2244 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2929.15(B)(1)(C)(I) — 3 cases
State v. Walsson, 2018 Ohio 4485 (Ohio Ct. App. 2018).
State v. Trice, 2019 Ohio 5098 (Ohio Ct. App. 2019).
State v. Bernhardt, 2020 Ohio 1639 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2929.15(B)(1)(a) — 19 cases
State v. Howard (Slip Opinion), 2020 Ohio 3195 (Ohio 2020). “] Sentencing—Community control—Consecutive sentences—R.C. 2929.15(B)—R.C. 2929.19(B)—R.C. 2929.”
State v. Taylor (Slip Opinion), 2020 Ohio 3514 (Ohio 2020).
State v. Crose, 2023 Ohio 880 (Ohio Ct. App. 2023).
State v. Batty, 2014 Ohio 2826 (Ohio Ct. App. 2014).
State v. Greene, 2024 Ohio 363 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2929.15(B)(1)(b) — 10 cases
State v. Ingledue, 2019 Ohio 397 (Ohio Ct. App. 2019).
State v. Howard (Slip Opinion), 2020 Ohio 3195 (Ohio 2020). “] Sentencing—Community control—Consecutive sentences—R.C. 2929.15(B)—R.C. 2929.19(B)—R.C. 2929.”
State v. Reed (Slip Opinion), 2020 Ohio 4255 (Ohio 2020).
State v. Struffolino, 2020 Ohio 1051 (Ohio Ct. App. 2020).
State v. Evans, 2021 Ohio 590 (Ohio Ct. App. 2021).
— Ohio Rev. Code § 2929.15(B)(1)(c) — 85 cases
State v. Nelson (Slip Opinion), 2020 Ohio 3690 (Ohio 2020). “{¶ 20} We also find that the interpretation of the term “technical violation” in Davis and Mannah makes sense when R.C. 2929.15 is viewed as a whole and that Nelson’s interpretation—that “technical violation” means any noncriminal violation—does not.”
State v. Neville, 2019 Ohio 151 (Ohio Ct. App. 2019). “She raises one assignment of error for our review: The trial court's twelve-month prison sentence for a technical violation of community control sanctions is contrary to law because it exceeded the 90-day maximum sentence authorized by R.C. 2929.15. {¶3} Finding no merit to her…”
State v. Calhoun, 2019 Ohio 228 (Ohio Ct. App. 2019). “{¶ 3} At that time, R.C. 2929.15(A)(1) stated: If in sentencing an offender for a felony the court is not required to impose a prison term, a mandatory prison term, or a term of life imprisonment upon the offender, the court may directly impose a sentence that consists of one or…”
State v. Davis, 2018 Ohio 2672 (Ohio Ct. App. 2018). “-5- Warren CA2017-11-156 {¶ 16} The appellate court observed that while "technical violation" was not defined in R.C. 2929.15, other appellate districts had addressed "technical violations" as they pertained to revocation of community control sanctions and parole violations in…”
State v. Walsson, 2018 Ohio 4485 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2929.15(B)(1)(c)(1) — 1 case
State v. Wodarski, 2022 Ohio 1428 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2929.15(B)(1)(c)(2) — 1 case
State v. King, 2020 Ohio 1512 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2929.15(B)(1)(c)(i) — 77 cases
State v. Neville, 2019 Ohio 151 (Ohio Ct. App. 2019). “She raises one assignment of error for our review: The trial court's twelve-month prison sentence for a technical violation of community control sanctions is contrary to law because it exceeded the 90-day maximum sentence authorized by R.C. 2929.15. {¶3} Finding no merit to her…”
State v. Calhoun, 2019 Ohio 228 (Ohio Ct. App. 2019). “{¶ 3} At that time, R.C. 2929.15(A)(1) stated: If in sentencing an offender for a felony the court is not required to impose a prison term, a mandatory prison term, or a term of life imprisonment upon the offender, the court may directly impose a sentence that consists of one or…”
State v. Nelson (Slip Opinion), 2020 Ohio 3690 (Ohio 2020). “{¶ 20} We also find that the interpretation of the term “technical violation” in Davis and Mannah makes sense when R.C. 2929.15 is viewed as a whole and that Nelson’s interpretation—that “technical violation” means any noncriminal violation—does not.”
State v. Baker, 2019 Ohio 2280 (Ohio Ct. App. 2019).
Smith v. Sheldon (Slip Opinion), 2019 Ohio 1677 (Ohio 2019).
— Ohio Rev. Code § 2929.15(B)(1)(c)(ii) — 35 cases
State v. Nelson (Slip Opinion), 2020 Ohio 3690 (Ohio 2020). “{¶ 20} We also find that the interpretation of the term “technical violation” in Davis and Mannah makes sense when R.C. 2929.15 is viewed as a whole and that Nelson’s interpretation—that “technical violation” means any noncriminal violation—does not.”
State v. Graham, 2019 Ohio 1485 (Ohio Ct. App. 2019).
State v. Davis, 2018 Ohio 2672 (Ohio Ct. App. 2018). “-5- Warren CA2017-11-156 {¶ 16} The appellate court observed that while "technical violation" was not defined in R.C. 2929.15, other appellate districts had addressed "technical violations" as they pertained to revocation of community control sanctions and parole violations in…”
State v. Hope, 2019 Ohio 3023 (Ohio Ct. App. 2019).
State v. Demangone, 2023 Ohio 2522 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2929.15(B)(2) — 28 cases
State v. Duncan, 2016 Ohio 5559 (Ohio Ct. App. 2016).
State v. Jones, 2020 Ohio 762 (Ohio Ct. App. 2020).
State v. Bika, 2019 Ohio 3841 (Ohio Ct. App. 2019).
State v. Prince, 2016 Ohio 2724 (Ohio Ct. App. 2016).
State v.Olverson, 2017 Ohio 9188 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2929.15(B)(2)(b) — 1 case
State v. P.J.F., 2022 Ohio 4152 (Ohio 2022).
— Ohio Rev. Code § 2929.15(B)(2)(b)(ii) — 1 case
State v. Farris, 2021 Ohio 2135 (Ohio Ct. App. 2021).
— Ohio Rev. Code § 2929.15(B)(3) — 40 cases
State v. Jones, 2022 Ohio 4485 (Ohio 2022).
State v. Neville, 2019 Ohio 151 (Ohio Ct. App. 2019). “She raises one assignment of error for our review: The trial court's twelve-month prison sentence for a technical violation of community control sanctions is contrary to law because it exceeded the 90-day maximum sentence authorized by R.C. 2929.15. {¶3} Finding no merit to her…”
State v. Howard (Slip Opinion), 2020 Ohio 3195 (Ohio 2020). “] Sentencing—Community control—Consecutive sentences—R.C. 2929.15(B)—R.C. 2929.19(B)—R.C. 2929.”
State v. Phipps, 2021 Ohio 258 (Ohio Ct. App. 2021).
State v. Calhoun, 2019 Ohio 228 (Ohio Ct. App. 2019). “{¶ 3} At that time, R.C. 2929.15(A)(1) stated: If in sentencing an offender for a felony the court is not required to impose a prison term, a mandatory prison term, or a term of life imprisonment upon the offender, the court may directly impose a sentence that consists of one or…”
— Ohio Rev. Code § 2929.15(B)(4) — 3 cases
State v. Elliot, 2023 Ohio 1459 (Ohio Ct. App. 2023).
State v. Van Den Eynde, 2023 Ohio 1790 (Ohio Ct. App. 2023).
State v. Armstrong, 2015 Ohio 4186 (Ohio Ct. App. 2015).
— Ohio Rev. Code § 2929.15(B)(5) — 8 cases
State v. Baker, 787 N.E.2d 17 (Ohio Ct. App. 2002).
State v. Lantz, 2019 Ohio 3307 (Ohio Ct. App. 2019).
State v. Elliot, 2023 Ohio 1459 (Ohio Ct. App. 2023).
State v. Kegley, 2016 Ohio 8467 (Ohio Ct. App. 2016).
State v. Thompson, 950 N.E.2d 1022 (Ohio Ct. App. 2011).
— Ohio Rev. Code § 2929.15(B)(c)(ii) — 1 case
State v. Stevens, 2019 Ohio 1838 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2929.15(B)(i)(c) — 1 case
State v. DiGrino, 2019 Ohio 3992 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2929.15(C) — 24 cases
State v. Aguirre (Slip Opinion), 2014 Ohio 4603 (Ohio 2014).
State v. Tate, 2022 Ohio 4745 (Ohio Ct. App. 2022).
State v. Weeks, 2021 Ohio 3735 (Ohio Ct. App. 2021).
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). “15(C) so as to automatically lessen the offender’s sanction. Any adjustment in the terms of community control requires court action.”
State v. Castillo, 2011 Ohio 1821 (Ohio Ct. App. 2011).
— Ohio Rev. Code § 2929.15(C)(2) — 1 case
Euclid v. Washington, 2026 Ohio 2081 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2929.15(E) — 21 cases
State v. Demangone, 2023 Ohio 2522 (Ohio Ct. App. 2023).
State v. Elliot, 2023 Ohio 1459 (Ohio Ct. App. 2023).
State v. Hogya, 2024 Ohio 639 (Ohio Ct. App. 2024).
State v. Cihon, 2023 Ohio 3108 (Ohio Ct. App. 2023).
State v. Crose, 2023 Ohio 880 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2929.15(E)(1) — 6 cases
State v. Crose, 2023 Ohio 880 (Ohio Ct. App. 2023).
State v. Everett, 2023 Ohio 1243 (Ohio Ct. App. 2023).
State v. Krouse, 2026 Ohio 409 (Ohio Ct. App. 2026).
State v. Helton, 2025 Ohio 1945 (Ohio Ct. App. 2025).
State v. Parker, 2022 Ohio 1115 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2929.15(E)(2) — 9 cases
State v. Hogya, 2024 Ohio 639 (Ohio Ct. App. 2024).
State v. Demangone, 2023 Ohio 2522 (Ohio Ct. App. 2023).
State v. Crose, 2023 Ohio 880 (Ohio Ct. App. 2023).
State v. McManus, 2024 Ohio 2588 (Ohio Ct. App. 2024).
State v. Helton, 2025 Ohio 1945 (Ohio Ct. App. 2025).
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