State v. Howard
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The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals affirming the decision of the trial court revoking Defendant's community control and imposing the prison sentence that it had notified Defendant of at his initial sentencing hearing, holding that consecutive sentences were not properly imposed in this case.
The court of appeals concluded (1) because the trial court had notified Defendant at his initial sentencing hearing of the specific prison terms that the court could impose if Defendant were to violate his community-control conditions, it was not required to repeat that notification before it imposed the prison terms at a second revocation hearing; and (2) the trial court had not been required to make consecutive-sentences findings required under Ohio Rev. Code 2929.14(c) when it revoked Defendant's community control and imposed consecutive prison terms. The Supreme Court reversed in part, holding (1) the trial court provided Defendant sufficient notice of the specific prison terms he could receive if his community control were to be revoked; but (2) a trial court must make statutorily required consecutive-sentences findings when it imposes consecutive sentences following the revocation of community control.
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