Ohio Rev. Code » Chapter 2929
Ohio Revised Code

Ohio Rev. Code § 2929.25 (2026)

Community control sanctions - misdemeanor

✓ current as of May 2026
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Effective:
April 4, 2023
Latest Legislation:
Senate Bill 288 - 134th General Assembly
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(A)(1) Except as provided in sections 2929.22 and 2929.23 of the Revised Code or when a jail term is required by law, in sentencing an offender for a misdemeanor, other than a minor misdemeanor, the sentencing court may do either of the following:

(a) Directly impose a sentence that consists of one or more community control sanctions authorized by section 2929.26, 2929.27, or 2929.28 of the Revised Code. The court may impose any other conditions of release under a community control sanction that the court considers appropriate. If the court imposes a jail term upon the offender, the court may impose any community control sanction or combination of community control sanctions in addition to the jail term.

(b) Impose a jail term under section 2929.24 of the Revised Code from the range of jail terms authorized under that section for the offense, suspend all or a portion of the jail term imposed, and place the offender under a community control sanction or combination of community control sanctions authorized under section 2929.26, 2929.27, or 2929.28 of the Revised Code.

(2) The duration of all community control sanctions imposed upon an offender and in effect for an offender at any time shall not exceed five years.

(3) At sentencing, if a court directly imposes a community control sanction or combination of community control sanctions pursuant to division (A)(1)(a) or (B) of this section, the court shall state the duration of the community control sanctions imposed and shall notify the offender that if any of the conditions of the community control sanctions are violated the court may do any of the following:

(a) Impose a longer time under the same community control sanction if the total time under all of the offender's community control sanctions does not exceed the five-year limit specified in division (A)(2) of this section;

(b) Impose a more restrictive community control sanction under section 2929.26, 2929.27, or 2929.28 of the Revised Code, but the court is not required to impose any particular sanction or sanctions;

(c) Impose a definite jail term from the range of jail terms authorized for the offense under section 2929.24 of the Revised Code.

(B) If a court sentences an offender to any community control sanction or combination of community control sanctions pursuant to division (A)(1)(a) of this section, the sentencing court retains jurisdiction over the offender and the period of community control for the duration of the period of community control. Upon the motion of either party or on the court's own motion, the court, in the court's sole discretion and as the circumstances warrant, may modify the community control sanctions or conditions of release previously imposed, substitute a community control sanction or condition of release for another community control sanction or condition of release previously imposed, or impose an additional community control sanction or condition of release.

(C)(1) If a court sentences an offender to any community control sanction or combination of community control sanctions authorized under section 2929.26, 2929.27, or 2929.28 of the Revised Code, the court shall place the offender under the general control and supervision of the court or of a department of probation in the jurisdiction that serves the court for purposes of reporting to the court a violation of any of the conditions of the sanctions imposed. If the offender resides in another jurisdiction and a department of probation has been established to serve the municipal court or county court in that jurisdiction, the sentencing court may request the municipal court or the county court to receive the offender into the general control and supervision of that department of probation for purposes of reporting to the sentencing court a violation of any of the conditions of the sanctions imposed. The sentencing court retains jurisdiction over any offender whom it sentences for the duration of the sanction or sanctions imposed.

(2) The sentencing court shall require as a condition of any community control sanction that the offender abide by the law and not leave the state without the permission of the court or the offender's probation officer. In the interests of doing justice, rehabilitating the offender, and ensuring the offender's good behavior, the court may impose additional requirements on the offender. The offender's compliance with the additional requirements also shall be a condition of the community control sanction imposed upon the offender.

(D)(1) If the court imposing sentence upon an offender sentences the offender to any community control sanction or combination of community control sanctions authorized under section 2929.26, 2929.27, or 2929.28 of the Revised Code, and if the offender violates any of the conditions of the sanctions, the public or private person or entity that supervises or administers the program or activity that comprises the sanction shall report the violation directly to the sentencing court or to the department of probation or probation officer with general control and supervision over the offender. If the public or private person or entity reports the violation to the department of probation or probation officer, the department or officer shall report the violation to the sentencing court.

(2) Except as provided in division (D)(3) of this section, if an offender violates any condition of a community control sanction, the sentencing court may impose upon the violator one or more of the following penalties:

(a) A longer time under the same community control sanction if the total time under all of the community control sanctions imposed on the violator does not exceed the five-year limit specified in division (A)(2) of this section;

(b) A more restrictive community control sanction;

(c) A combination of community control sanctions, including a jail term.

(3) If an offender was acting pursuant to division (B)(2)(b) of section 2925.11 or a related provision under 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 (D)(2) of this section based on the violation.

(4) If the court imposes a jail term upon a violator pursuant to division (D)(2) of this section, the total time spent in jail for the misdemeanor offense and the violation of a condition of the community control sanction shall not exceed the maximum jail term available for the offense for which the sanction that was violated was imposed. The court may reduce the longer period of time that the violator is required to spend under the longer sanction or the more restrictive sanction imposed under division (D)(2) of this section by all or part of the time the violator successfully spent under the sanction that was initially imposed.

(E) Except as otherwise provided in this division, if an offender, for a significant period of time, fulfills the conditions of a community control sanction imposed pursuant to section 2929.26, 2929.27, or 2929.28 of the Revised Code in an exemplary manner, the court may reduce the period of time under the community control sanction or impose a less restrictive community control sanction. Fulfilling the conditions of a community control sanction does not relieve the offender of a duty to make restitution under section 2929.28 of the Revised Code.

Last updated February 17, 2023 at 4:48 PM

Notes of Decisions
Cited in 257 cases (106 in the last 5 years), 1997–2026 · leading case: State v. Floyd, 2018-Ohio-5107, 126 N.E.3d 361.
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State v. Floyd, 2018-Ohio-5107, 126 N.E.3d 361. · cites it 16× “25 gives a trial court two options when sentencing a misdemeanor offender to community control: (1) directly impose a sentence that consists of a community-control sanction; or (2) impose a jail term under R.”
Walton Hills v. Olesinski, 2020-Ohio-5618. · cites it 17× “The ordinances do not govern the trial court’s discretion to impose community-control sanctions under R.C. 2929.25 and 2929.27. Thus, Olesinski’s constitutional arguments, in effect, challenge the language contained within the ordinances supporting his underlying convictions.”
Cleveland v. S.W. Invests., L.L.C., 2024-Ohio-1271. · cites it 9× “Further, if the court finds a defendant in violation of community-control sanctions, it may impose one or more of the following penalties: (1) a longer time under the same community-control sanction so long as the total time does not exceed five years; (2) a more restrictive…”
State v. Bishop (Slip Opinion), 2018-Ohio-5132, 124 N.E.3d 766. · cites it 2× “See generally R.C. 2929.25(A)(3)(c); State v. Jones, 2017- Ohio-943, 86 N.”
State v. Everson, 2018-Ohio-323. · cites it 8× “The court may (1) “[d]irectly impose a sentence that consists of one or more community control sanctions * * *,” or (2) impose a jail term, suspend all or part of the jail term, and place the defendant under community control sanctions.”
State v. Sutton, 835 N.E.2d 752 (Ohio Ct. App. 2005). · cites it 17× “19(B)(5) concern felony sentencing, whereas R.C. 2929.25 applies to misdemeanor cases.”
State v. Blankenship, 949 N.E.2d 1087 (Ohio Ct. App. 2011). · cites it 7× “R.C. 2929.25(A)(1). The range of available community-control sanctions includes residential sanctions, such as a term in a halfway house; nonresidential sanctions, such as a period of house arrest; and financial sanctions, such as restitution.”
State v. Cintron, 2022-Ohio-305. · cites it 6× “The trial court abused its discretion under R.C. 2929.25 when it ordered that Mr. Cintron pay child support.”
Cleveland v. Kushlak, 2024-Ohio-973. · cites it 35× “The city contends that based upon the finding of a violation, the municipal court was authorized to modify Kushlak’s community-control conditions pursuant to R.C. 2929.25. Additionally, the city argues that any modification listed in the February 10, 2023 judgment entry is not…”
State v. Snell, 2019-Ohio-2251. · cites it 14× “Snell argued that the no-contact order was contrary to law because the trial court failed to state a duration of time for the order as required by R.C. 2929.25. After reviewing the motion, the trial court held a resentencing hearing on August 13, 2018.”
Cleveland v. Kushlak, 2022-Ohio-4402, 203 N.E.3d 160. · cites it 8× “If the offender violates any condition of the community control sanctions, the sentencing court may impose “one or more” of the following: (1) a longer period of community control provided that it does not exceed five years; (2) a more restrictive community control sanction; (3)…”
State v. Zappa, 2022-Ohio-243, 183 N.E.3d 1270. · cites it 4× “{¶36} A trial court also has the discretion to “substitute one or more community control sanctions under [R.”
Show all 257 citing cases →
Ohio Rev. Code § 2929.25(2): 2 cases
State v. Ogle, 2013-Ohio-3420.
State v. Moschell, 2020-Ohio-6818.
Ohio Rev. Code § 2929.25(2)(a): 1 case
Cleveland v. Sopjack, 2024-Ohio-6018.
Ohio Rev. Code § 2929.25(A): 47 cases
State v. Fry, 2017-Ohio-9077.
Westlake v. Y.O., 2019-Ohio-2432.
State v. Garrison, 2018-Ohio-463.
State v. Florence, 2014-Ohio-2337.
State v. Wilson, 2018-Ohio-2805.
Ohio Rev. Code § 2929.25(A)(1): 28 cases
State v. Blankenship, 949 N.E.2d 1087 (Ohio Ct. App. 2011). “R.C. 2929.25(A)(1). The range of available community-control sanctions includes residential sanctions, such as a term in a halfway house; nonresidential sanctions, such as a period of house arrest; and financial sanctions, such as restitution.”
Cleveland v. S.W. Invests., L.L.C., 2024-Ohio-1271. “Further, if the court finds a defendant in violation of community-control sanctions, it may impose one or more of the following penalties: (1) a longer time under the same community-control sanction so long as the total time does not exceed five years; (2) a more restrictive…”
Conneaut v. Pushic, 2025-Ohio-1783.
State v. Cowen, 854 N.E.2d 579 (Ohio Ct. App. 2006).
State v. Pierce, 2011-Ohio-4873.
Ohio Rev. Code § 2929.25(A)(1)(a): 42 cases
Cleveland v. Kushlak, 2022-Ohio-4402, 203 N.E.3d 160. “If the offender violates any condition of the community control sanctions, the sentencing court may impose “one or more” of the following: (1) a longer period of community control provided that it does not exceed five years; (2) a more restrictive community control sanction; (3)…”
Cleveland v. S.W. Invests., L.L.C., 2024-Ohio-1271. “Further, if the court finds a defendant in violation of community-control sanctions, it may impose one or more of the following penalties: (1) a longer time under the same community-control sanction so long as the total time does not exceed five years; (2) a more restrictive…”
State v. Floyd, 2018-Ohio-5107, 126 N.E.3d 361. “25 gives a trial court two options when sentencing a misdemeanor offender to community control: (1) directly impose a sentence that consists of a community-control sanction; or (2) impose a jail term under R.”
Cleveland v. Kushlak, 2024-Ohio-973. “The city contends that based upon the finding of a violation, the municipal court was authorized to modify Kushlak’s community-control conditions pursuant to R.C. 2929.25. Additionally, the city argues that any modification listed in the February 10, 2023 judgment entry is not…”
Walton Hills v. Olesinski, 2020-Ohio-5618. “The ordinances do not govern the trial court’s discretion to impose community-control sanctions under R.C. 2929.25 and 2929.27. Thus, Olesinski’s constitutional arguments, in effect, challenge the language contained within the ordinances supporting his underlying convictions.”
Ohio Rev. Code § 2929.25(A)(1)(b): 34 cases
State v. Zappa, 2022-Ohio-243, 183 N.E.3d 1270. “{¶36} A trial court also has the discretion to “substitute one or more community control sanctions under [R.”
State v. Henry, 2016-Ohio-680.
State v. Everson, 2018-Ohio-323. “The court may (1) “[d]irectly impose a sentence that consists of one or more community control sanctions * * *,” or (2) impose a jail term, suspend all or part of the jail term, and place the defendant under community control sanctions.”
State v. Pope, 2014-Ohio-2864.
State v. Jones, 2020-Ohio-1273, 153 N.E.3d 689.
Ohio Rev. Code § 2929.25(A)(2): 30 cases
State v. Snell, 2019-Ohio-2251. “Snell argued that the no-contact order was contrary to law because the trial court failed to state a duration of time for the order as required by R.C. 2929.25. After reviewing the motion, the trial court held a resentencing hearing on August 13, 2018.”
State v. Blankenship, 949 N.E.2d 1087 (Ohio Ct. App. 2011). “R.C. 2929.25(A)(1). The range of available community-control sanctions includes residential sanctions, such as a term in a halfway house; nonresidential sanctions, such as a period of house arrest; and financial sanctions, such as restitution.”
State v. Bechtel, 2020-Ohio-4889.
State v. Thames, 2022-Ohio-1715.
State v. Coll, 2017-Ohio-7270, 96 N.E.3d 947.
Ohio Rev. Code § 2929.25(A)(3): 20 cases
State v. Everson, 2018-Ohio-323. “The court may (1) “[d]irectly impose a sentence that consists of one or more community control sanctions * * *,” or (2) impose a jail term, suspend all or part of the jail term, and place the defendant under community control sanctions.”
State v. Sutton, 835 N.E.2d 752 (Ohio Ct. App. 2005). “19(B)(5) concern felony sentencing, whereas R.C. 2929.25 applies to misdemeanor cases.”
State v. Russell, 2011-Ohio-1181.
Cleveland v. Schornstein Holdings, L.L.C., 2016-Ohio-7479, 73 N.E.3d 889.
State v. Geiger, 862 N.E.2d 914 (Ohio Ct. App. 2006).
Ohio Rev. Code § 2929.25(A)(3)(a): 4 cases
State v. Sutton, 835 N.E.2d 752 (Ohio Ct. App. 2005). “19(B)(5) concern felony sentencing, whereas R.C. 2929.25 applies to misdemeanor cases.”
State v. Coffer, 2020-Ohio-994.
State v. Shorter, 22188 (4-25-2008), 2008 Ohio 1986 (Ohio Ct. App. 2008).
State v. Wacker, 2019-Ohio-3997.
Ohio Rev. Code § 2929.25(A)(3)(c): 8 cases
State v. Bishop (Slip Opinion), 2018-Ohio-5132, 124 N.E.3d 766. “See generally R.C. 2929.25(A)(3)(c); State v. Jones, 2017- Ohio-943, 86 N.”
State v. Bailey, 2016-Ohio-4937.
State v. Sutton, 835 N.E.2d 752 (Ohio Ct. App. 2005). “19(B)(5) concern felony sentencing, whereas R.C. 2929.25 applies to misdemeanor cases.”
State v. Gibson, 2014-Ohio-433.
State v. Coffer, 2020-Ohio-994.
Ohio Rev. Code § 2929.25(A)(3)(e): 1 case
State v. Sutton, 835 N.E.2d 752 (Ohio Ct. App. 2005). “19(B)(5) concern felony sentencing, whereas R.C. 2929.25 applies to misdemeanor cases.”
Ohio Rev. Code § 2929.25(B): 24 cases
State v. Floyd, 2018-Ohio-5107, 126 N.E.3d 361. “25 gives a trial court two options when sentencing a misdemeanor offender to community control: (1) directly impose a sentence that consists of a community-control sanction; or (2) impose a jail term under R.”
Walton Hills v. Olesinski, 2020-Ohio-5618. “The ordinances do not govern the trial court’s discretion to impose community-control sanctions under R.C. 2929.25 and 2929.27. Thus, Olesinski’s constitutional arguments, in effect, challenge the language contained within the ordinances supporting his underlying convictions.”
Bay Vill. v. Barringer, 2015-Ohio-4079.
Cleveland v. Kushlak, 2024-Ohio-973. “The city contends that based upon the finding of a violation, the municipal court was authorized to modify Kushlak’s community-control conditions pursuant to R.C. 2929.25. Additionally, the city argues that any modification listed in the February 10, 2023 judgment entry is not…”
Miamisburg v. Hanson, 2016-Ohio-964, 49 N.E.3d 336.
Ohio Rev. Code § 2929.25(B)(1): 5 cases
State v. Snell, 2019-Ohio-2251. “Snell argued that the no-contact order was contrary to law because the trial court failed to state a duration of time for the order as required by R.C. 2929.25. After reviewing the motion, the trial court held a resentencing hearing on August 13, 2018.”
State v. Johnson, 2010-Ohio-2533.
State v. Carr, 2021-Ohio-4556.
State v. Yerkey, 2024-Ohio-4849.
State v. Hosler, 2010-Ohio-980.
Ohio Rev. Code § 2929.25(B)(2): 1 case
State v. Lewis, 2011-Ohio-4603.
Ohio Rev. Code § 2929.25(C): 9 cases
State v. Floyd, 2018-Ohio-5107, 126 N.E.3d 361. “25 gives a trial court two options when sentencing a misdemeanor offender to community control: (1) directly impose a sentence that consists of a community-control sanction; or (2) impose a jail term under R.”
State v. Baker, 2021-Ohio-272.
Walton Hills v. Olesinski, 2020-Ohio-5618. “The ordinances do not govern the trial court’s discretion to impose community-control sanctions under R.C. 2929.25 and 2929.27. Thus, Olesinski’s constitutional arguments, in effect, challenge the language contained within the ordinances supporting his underlying convictions.”
State v. J.M.S, 2019-Ohio-3383.
Cleveland v. ProTerra, Inc., 2021-Ohio-1086.
Ohio Rev. Code § 2929.25(C)(1): 3 cases
State v. Cintron, 2022-Ohio-305. “The trial court abused its discretion under R.C. 2929.25 when it ordered that Mr. Cintron pay child support.”
State v. Marlow, 2019-Ohio-3393.
State v. Hiles, 2019-Ohio-3330.
Ohio Rev. Code § 2929.25(C)(2): 26 cases
State v. Blankenship, 949 N.E.2d 1087 (Ohio Ct. App. 2011). “R.C. 2929.25(A)(1). The range of available community-control sanctions includes residential sanctions, such as a term in a halfway house; nonresidential sanctions, such as a period of house arrest; and financial sanctions, such as restitution.”
State v. Ice, 2024-Ohio-5341, 257 N.E.3d 492.
State v. Cintron, 2022-Ohio-305. “The trial court abused its discretion under R.C. 2929.25 when it ordered that Mr. Cintron pay child support.”
State v. Wagener, 2022-Ohio-724.
Cleveland v. Dickerson, 2016-Ohio-806, 60 N.E.3d 686.
Ohio Rev. Code § 2929.25(C)(3): 1 case
State v. Blankenship, 949 N.E.2d 1087 (Ohio Ct. App. 2011). “R.C. 2929.25(A)(1). The range of available community-control sanctions includes residential sanctions, such as a term in a halfway house; nonresidential sanctions, such as a period of house arrest; and financial sanctions, such as restitution.”
Ohio Rev. Code § 2929.25(D): 7 cases
Walton Hills v. Olesinski, 2020-Ohio-5618. “The ordinances do not govern the trial court’s discretion to impose community-control sanctions under R.C. 2929.25 and 2929.27. Thus, Olesinski’s constitutional arguments, in effect, challenge the language contained within the ordinances supporting his underlying convictions.”
Bay Vill. v. Barringer, 2015-Ohio-4079.
State v. Wells, 2021-Ohio-2343.
Olmsted Twp. v. Ritchie, 2022-Ohio-124, 181 N.E.3d 649.
State v. Richter, 2014-Ohio-5396.
Ohio Rev. Code § 2929.25(D)(1): 2 cases
Cleveland v. Cornely, 2021-Ohio-3459.
State v. Strohl, 2018-Ohio-4266.
Ohio Rev. Code § 2929.25(D)(2): 20 cases
Cleveland v. Schornstein Holdings, L.L.C., 2016-Ohio-7479, 73 N.E.3d 889.
Cleveland v. Kushlak, 2024-Ohio-973. “The city contends that based upon the finding of a violation, the municipal court was authorized to modify Kushlak’s community-control conditions pursuant to R.C. 2929.25. Additionally, the city argues that any modification listed in the February 10, 2023 judgment entry is not…”
Cleveland v. S.W. Invests., L.L.C., 2024-Ohio-1271. “Further, if the court finds a defendant in violation of community-control sanctions, it may impose one or more of the following penalties: (1) a longer time under the same community-control sanction so long as the total time does not exceed five years; (2) a more restrictive…”
State v. Jones, 2020-Ohio-1273, 153 N.E.3d 689.
State v. Saxon, 2017-Ohio-93.
Ohio Rev. Code § 2929.25(D)(2)(a): 6 cases
State v. Taylor (Slip Opinion), 2020-Ohio-3514, 163 N.E.3d 486.
Cleveland v. Kushlak, 2024-Ohio-973. “The city contends that based upon the finding of a violation, the municipal court was authorized to modify Kushlak’s community-control conditions pursuant to R.C. 2929.25. Additionally, the city argues that any modification listed in the February 10, 2023 judgment entry is not…”
State v. Sayers, 2023-Ohio-672.
Cleveland v. Sopjack, 2024-Ohio-6018.
State v. Briskey, 2012-Ohio-5340.
Ohio Rev. Code § 2929.25(D)(2)(c): 5 cases
Olmsted Twp. v. Ritchie, 2022-Ohio-124, 181 N.E.3d 649.
State v. Levesque, 2025-Ohio-2834.
State v. Battigaglia, 2021-Ohio-1781.
State v. Strohl, 2018-Ohio-4266.
State v. McCleary, 2025-Ohio-5213.
Ohio Rev. Code § 2929.25(D)(3): 4 cases
State v. Wallace, 2013-Ohio-2871.
State v. Harris, 2012-Ohio-5612.
State v. Daniel, 2015-Ohio-3826.
State v. Richter, 2014-Ohio-5396.
Ohio Rev. Code § 2929.25(D)(4): 4 cases
Olmsted Twp. v. Ritchie, 2022-Ohio-124, 181 N.E.3d 649.
State v. Barnes, 2022-Ohio-1738.
State v. Grose, 2026-Ohio-2011.
State v. Houk, 2021-Ohio-4618.
Ohio Rev. Code § 2929.25(F): 3 cases
State v. Garrison, 2018-Ohio-1048.
State v. Stoneking, 2021-Ohio-1307.
State v. Laney, 2023-Ohio-1058.
Ohio Rev. Code § 2929.25(F)(1)(a)(i): 1 case
State v. Jackson-Williams, 2020-Ohio-1118.
Ohio Rev. Code § 2929.25(F)(1)(b): 1 case
State v. Jenkins, 2018-Ohio-3697.
Ohio Rev. Code § 2929.25(a)(3): 1 case
State v. Sutton, 835 N.E.2d 752 (Ohio Ct. App. 2005). “19(B)(5) concern felony sentencing, whereas R.C. 2929.25 applies to misdemeanor cases.”
Ohio Rev. Code § 2929.25(c): 1 case
State v. Kergan, 2012-Ohio-1407.
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