State v. Bell, 2011 Ohio 6799

Bell was convicted of possession of heroin (more than one gram, less than five) a fourth-degree felony; sentence included a reserved term of 15 months in prison if community control was violated.
A Notice of Community Control Sanction Revocation Hearing was filed alleging violation of conditions (primarily leaving a treatment program and failing to report to his probation officer).
A revocation hearing on May 20, 2011 found violations of community control and the court sentenced Bell to eight months in prison after allocution.
Bell completed his eight-month sentence by November 2011, with jail credit reflected in court entries; the record shows he was in custody at the revocation/sentencing time.
Appointed counsel filed an Anders brief asserting no nonfrivolous issues; Bell did not file a pro se brief.
The appellate court granted counsel’s withdrawal and affirmed the trial court’s judgment as moot with respect to the underlying conviction and potential issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation of community control and eight-month sentence was an abuse of discretion.	Bell	Bell	Moot; no merit in issues since sentence served.
Whether the Anders review was proper given potential issues were moot.	Bell	Bell	Anders review found no nonfrivolous issues; court affirmed.

State v. Johnson, Lake App. No.2005-L-208, 2007-Ohio-780 (Ohio (appellate) 2007) (mootness when underlying issues unrelated to conviction)
State v. Money, 2010-Ohio-6225 (Ohio App. 2010) (mootness where sentence served)
State v. Silvers, 2010-Ohio-567 (Ohio App. 2010) (mootness doctrine applied to sentence challenge)
Anders v. California, 386 U.S. 738 (U.S. 1967) (procedural framework for counsel to seek withdrawal when no nonfrivolous issues exist)