State v. Abrams, 2016 Ohio 5581

Jamalia Abrams pleaded guilty to aggravated robbery (1st-degree felony) and felonious assault (2nd-degree felony); court sentenced her to concurrent four-year terms (total four years).
After serving 29 months, Abrams filed a pro se motion for judicial release; the trial court granted it and imposed a two-year community-control sanction, suspending the remaining balance of her sentence.
The trial court expressly reserved the right to reimpose the original sentence if Abrams violated community control, and the judgment entry noted that violation would result in re-incarceration to complete the previously ordered sentence.
Abrams admitted to a probation violation, and the trial court revoked judicial release and reimposed the remaining 13 months of her original four-year term.
On appeal, Abrams argued the trial court failed to orally notify her at the judicial-release hearing of the specific prison term that would be imposed upon violation, seeking reversal under the notice requirements applicable to community-control sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court could reimpose the suspended remainder of the original sentence after judicial release revocation	State: Trial court properly reimposed the original sentence under R.C. 2929.20	Abrams: Court was required to orally state the specific prison term she would face upon violation (relying on Brooks and R.C. 2929.15)	Court held trial court properly reimposed the balance under R.C. 2929.20; heightened Brooks notice was not required because this was judicial release, not original community-control sentencing

State v. Brooks, 814 N.E.2d 837 (Ohio 2004) (trial court must notify offender of specific prison term that may be imposed when originally sentencing to community control)
Rollins v. Haviland, 757 N.E.2d 769 (Ohio 2001) (no inherent right to early release; once sentence executed, court lacks authority to modify absent statutory authorization)