State v. Cintron, 2022 Ohio 305

Cintron was indicted for breaking and entering and pleaded guilty to attempted breaking and entering (first-degree misdemeanor) pursuant to a plea agreement.
At sentencing the court suspended a six-month jail term and imposed one year of community-control sanctions.
Among conditions the court ordered Cintron to obtain verifiable employment and to “pay court ordered child support within 60 days,” although no formal child-support order then existed.
Cintron moved to stay execution of the child-support requirement and appealed, arguing the criminal court lacked jurisdiction to order child support and that the condition was unrelated to his offense and violated privacy.
The trial court stayed the child-support requirement pending appeal; the appellate court reviewed jurisdiction and whether the child-support condition was a permissible community-control sanction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the criminal common pleas court lacked jurisdiction to impose a child-support condition (void ab initio)	Court/State: common pleas had jurisdiction over the criminal case and could impose community-control conditions.	Cintron: imposing child-support obligations exceeds criminal-division jurisdiction and should be void.	Overruled — court had subject-matter and personal jurisdiction; any error was voidable, not void.
Whether ordering Cintron to pay/establish child support as a community-control condition was an abuse of discretion under R.C. 2929.25	Court/State: community-control conditions may be broad and related to rehabilitation/justice.	Cintron: the condition is unrelated to the breaking-and-entering offense and does not further rehabilitation or prevent future criminality.	Sustained — appellate court vacated the child-support condition as not reasonably related to the offense or rehabilitation and remanded.
Whether trial counsel rendered ineffective assistance by failing to object to the child-support condition	State: condition proper or objection not preserved.	Cintron: counsel’s failure to object deprived him of effective assistance.	Moot — disposition of the second issue mooted the ineffective-assistance claim.

State v. Henderson, 161 Ohio St.3d 285 (2020) (a sentence is void only if the court lacked subject-matter or personal jurisdiction)
State v. Mbodji, 129 Ohio St.3d 325 (2011) (definition and scope of jurisdiction)
State v. Jones, 49 Ohio St.3d 51 (1990) (probation/community-control-condition test: relation to rehabilitation, relation to offense, relation to future criminality)
State v. Talty, 103 Ohio St.3d 177 (2004) (invalid probation condition does not affect other valid conditions)
Ex parte Van Hagan, 25 Ohio St. (1874) (sentence in excess of lawful authority is erroneous/voidable rather than absolutely void)
State ex rel. Tubbs Jones v. Suster, 84 Ohio St.3d 70 (1998) (common pleas court jurisdiction over crimes)