State v. Caldwell, 2022 Ohio 4035

In June 2019 Caleb pled guilty to three counts involving sexual conduct with a minor and was placed on five years of community control and designated a Tier II sex offender. The court warned prison terms could be imposed if community control was revoked.
Key community-control conditions: obey laws; do not leave Ohio without written court permission; do not possess internet-capable electronic devices unless Covenant Eyes monitoring software was installed.
The court later authorized limited internet-capable device use for business only, contingent on installing Covenant Eyes; Caldwell never installed the software.
In September 2021 Caldwell responded to an online Listcrawler advertisement and was arrested in Boone County, Kentucky on a solicitation-of-prostitution operation; probation filed a violation report for leaving Ohio without permission and possessing an internet-capable device.
At a March 7, 2022 revocation hearing the trial court found violations of the travel and device conditions, revoked community control, and imposed concurrent prison terms (18, 12, and 18 months). Caldwell appealed raising three assignments of error (insufficient evidence to revoke; due-process defects at revocation; sentence contrary to law).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to revoke community control	State: presented substantial evidence Caldwell left Ohio without written permission and used an internet-capable device to solicit prostitution.	Caldwell: contested the sufficiency; claimed he notified probation after arrest and disputed travel-condition modification.	Court: No abuse of discretion—substantial evidence supported violations of the travel and device conditions; revocation affirmed.
Due process at revocation hearing (written statement & notice)	State: oral statement of reasons and evidence at hearing satisfied due process; Caldwell had notice and opportunity to be heard.	Caldwell: trial court failed to issue a written statement of the evidence/reasons and alleged defective notice of claimed violations.	Court: Oral on-the-record reasons and opportunity to confront witnesses satisfied due process; no violation.
Sentence contrary to law / clerical accuracy of entry	State: R.C. 2929.15(B) gives trial court discretion to impose prison within original range; court considered sentencing statutes.	Caldwell: argued sentence was contrary to law and raised ex parte-entry concerns; pointed out discrepancy with initial reserved term.	Court: Sentence within permissible statutory authority and sentencing considerations; but noted clerical discrepancy regarding a reserved 12-month term and remanded for a nunc pro tunc entry to correct the record.

State v. Delaney, 11 Ohio St.3d 231 (1984) (an oral statement of reasons for revocation can satisfy due-process requirements at a probation-revocation hearing)
State v. Jones, 163 Ohio St.3d 242 (2020) (appellate courts cannot independently reweigh whether the record satisfies R.C. 2929.11 or R.C. 2929.12 under R.C. 2953.08(G)(2))
State v. Roberts, 110 Ohio St.3d 71 (2006) (addresses due-process concerns from ex parte communications in postconviction and sentencing contexts; distinguished on the facts here)