State v. Arnold, 2019 Ohio 254

In March 2015 Brian Timothy Arnold was indicted for aggravated robbery and robbery; he ultimately pleaded guilty to aggravated robbery and was sentenced in May 2016 to three years in prison with a mandatory five-year term of postrelease control.
Arnold obtained judicial release in April 2017 after ~11 months and was placed on two years of community-control-like supervision with conditions (probation supervision, reporting, programming, fees, random drug tests), with the court reserving the right to reimpose the sentence on violation.
Between October 2017 and June 2018 the court held multiple judicial-release violation hearings for positive drug tests and for being unsuccessfully discharged from a treatment program for inappropriate/belligerent behavior toward staff.
At the June 2018 hearing the court found Arnold violated judicial release (discharge from treatment for vulgar/intimidating conduct), terminated judicial release, and reimposed the balance of his three-year sentence plus postrelease control.
Arnold appealed; appointed counsel filed an Anders brief asserting no meritorious issues and moved to withdraw. The court conducted an independent review; Arnold did not file a pro se brief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court abuse its discretion in revoking Arnold's judicial release?	State: substantial proof of violations (positive drug tests; unsuccessful discharge from treatment for inappropriate/belligerent behavior) justified revocation.	Arnold: asserted mental-health issues, cited employment and argued prison was inappropriate.	No abuse of discretion; revocation and reimposition of sentence affirmed.
Was counsel's Anders motion to withdraw appropriate and should the appeal be dismissed?	Appointed counsel: after review, no meritorious appellate issues; complied with Anders and local rule.	Arnold: did not file a pro se brief or identify arguable issues.	Court granted counsel's motion, dismissed the appeal after independent review.

Anders v. California, 386 U.S. 738 (1967) (appointed counsel must file a brief identifying any arguable issues before seeking withdrawal)
State v. Westrick, 196 Ohio App.3d 141 (Ohio Ct. App. 2011) (judicial-release revocation requires substantial proof and is reviewed for abuse of discretion)