State v. Chapman, 2019 Ohio 3535

Defendant London Chapman pled guilty to eleven counts of felony non-support across six child-support cases and faced community control.
The trial court announced it would impose an anti‑procreation condition and invited briefing on its constitutionality.
The court sentenced Chapman to five years of community control and ordered he "make all reasonable efforts to avoid impregnating a woman" during supervision until he can prove ability to support existing children; it also ordered restitution and past child‑support arrearages totaling over $220,000.
On initial appeal this Court rejected Chapman’s non‑constitutional challenges but remanded for the trial court to address Chapman’s constitutional arguments.
On remand the trial court rejected the constitutional challenge and reimposed the anti‑procreation condition and the restitution award; Chapman appealed.
This Court affirms, overruling Chapman’s constitutional challenge and rejecting his argument about the form of the restitution award as forfeited.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of anti‑procreation community‑control condition	State: Condition is a permissible probation/community‑control condition evaluated under State v. Jones test, not strict scrutiny	Chapman: Condition infringes fundamental right to procreate and requires strict‑scrutiny (narrowly tailored to compelling interest)	Court: Apply Jones test (not strict scrutiny); prior non‑constitutional challenges barred by law‑of‑the‑case; condition upheld
Lump‑sum restitution/arrearage award	State: Trial court properly ordered restitution and arrearages (amounts not challenged)	Chapman: Trial court should have itemized restitution vs. arrears (important for possible forgiveness/reduction); challenges to timeframe abandoned	Court: Issue forfeited for appeal (no objection below); not considered on merits

State v. Jones, 49 Ohio St.3d 51 (probation‑condition test governing validity of conditions)
Nolan v. Nolan, 11 Ohio St.3d 1 (law‑of‑the‑case doctrine)
State v. Fischer, 128 Ohio St.3d 92 (res judicata and issue preclusion principles)
State v. Ketterer, 126 Ohio St.3d 448 (res judicata bars claims raised or that could have been raised on appeal)
State v. Saxon, 109 Ohio St.3d 176 (finality and judicial economy in criminal appeals)
State v. Talty, 103 Ohio St.3d 177 (community‑control sanctions evaluated under Jones test)
State v. Lowe, 112 Ohio St.3d 507 (discussion of strict‑scrutiny standards for fundamental rights)
State v. Conkle, 129 Ohio App.3d 177 (upholding probation condition that implicates fundamental rights under Jones test)