State v. Brown, 2017 Ohio 8997

Defendant David Michael Brown pleaded guilty in 2017 to Having Weapons While Under Disability and agreed to a nine-month prison term to run consecutive to post-release control (PRC) time.
The trial court imposed a nine-month sentence consecutive to 487 days of PRC time and entered judgment accordingly on May 16, 2017.
Brown challenged the imposition of 487 days of PRC, arguing his 2002 convictions (2002 CR 497 and 2002 CR 573) lacked proper PRC advisements at sentencing, so PRC authority was invalid.
The appellate record did not include the 2002 sentencing transcripts or certified judgment entries from those prior cases; the State’s copies were attached only to its brief and were not part of the trial-court record.
The court applied the presumption of regularity to the absent prior-record materials and declined to consider documents not in the trial-court record, finding no reviewable evidence of any defect in the prior advisements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PRC time (487 days) imposed in 2017 sentence was invalid because prior 2002 cases lacked proper PRC advisements	State: PRC was properly imposed and supported by the record	Brown: 2002 sentencing failed to properly notify him of mandatory PRC, so APA’s authority and PRC in 2017 are null	Court affirmed: because the record lacks transcripts or certified entries from the 2002 cases, court presumed regularity and overruled Brown’s claim

Natl. City Bank v. Beyer, 89 Ohio St.3d 152 (assumption of regularity when hearing transcript not in record)
State v. Hooks, 92 Ohio St.3d 83 (2001) (courts cannot add matters outside record for appellate review)
State v. Ray, 181 Ohio App.3d 590 (2009) (appellant bears burden to show trial court error from the appellate record)