Department of Liquor Control v. Calvert, 961 N.E.2d 247

Mayo Bail Bond posted a $1,250 surety bond for Vernon Calvert after arrest on July 4, 2010.
Calvert pleaded no contest July 6, 2010; sentencing was continued to August 10, 2010.
Calvert failed to appear at sentencing; a bench warrant issued and a bond-revocation hearing set for August 24, 2010.
On August 24, 2010, a forfeiture of the bond was ordered when Calvert and Mayo did not appear; notices were sent to Mayo.
A September 20, 2010 notice advised a hearing and October 1, 2010 emergency proceeding; Mayo failed to appear at October 1, 2010.
On October 5, 2010, the court ordered a bond-revocation hearing within 30 days; a November 9, 2010 hearing was scheduled and notice sent to Mayo.
November 9, 2010 judgment stated that Calvert and bondsperson did not appear and that the bond was forfeited; Mayo was ordered to pay within 30 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2937.36 notice compliance was proper	Mayo argues improper notice violated the statute and prejudiced her.	State contends substantial compliance or no prejudice since notice allowed later show-cause.	No abuse for insufficient notice; prejudice not shown.
Whether the final judgment must specify a dollar amount	Judgment should specify the penalty amount within the bond limit.	Judgment stating ‘pay in bond’ suffices under R.C. 2937.36.	Final judgment must state a specific monetary amount.

State v. Hughes, 27 Ohio St.3d 19 (1986) (bail and recognizance concepts in Ohio)
State v. Scherer, 108 Ohio App.3d 586 (1995) (surety bond definitions and forfeiture procedures)
Harkai v. Scherba Indus. Inc., 136 Ohio App.3d 211 (2000) (judgment authority and proper signing)
State v. Barnes, 2011-Ohio-799 (2011) (abuse-of-discretion review in forfeiture judgments)
State v. Ward, 53 Ohio St.2d 40 (1978) (timeliness and prejudice standards for notice and show-cause requirements)