State v. Davis, 2012 Ohio 2499

Davis pled guilty to burglary (a second-degree felony) in 2009 in exchange for dismissal of another theft count.
Original sentencing: eight-year prison term suspended; placed on five years' probation; court warned that violations could lead to more restrictive sanctions or an eight-year term.
Journal entry reflected five years of community control with conditions; stated that violations may result in an eight-year prison term.
August 2009 probation-violation hearing found Davis in violation, terminated probation, and ordered the original sentence into execution; Davis challenged in Davis I.
On remand (July 2011), court accepted Davis’s waiver of a probation-violation hearing, found violation, and ordered the original sentence into execution, with postrelease control to be imposed after prison release.
Davis appeals, arguing the court never announced an eight-year prison term in open court and that Davis’s original sentence was community-control sanctions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the prison term was properly imposed without explicit open-court announcement	Davis argues no explicit prison term was pronounced; original sentence was mischaracterized as community control.	Davis contends the court extended community-control sanctions, not imposed a term of imprisonment.	Prison term impliedly imposed; plain error absent; judgment affirmed.
Whether res judicata or other constraints affect review of the sentencing	Davis suggests issues were or could have been raised previously, potentially barring reconsideration.	State argues res judicata may bar, but the court proceeds to the merits.	Court addresses merits; res judicata potential bar acknowledged but merits reached.

State v. Davis, 2012-Ohio-2499 (Ohio 2012) (appeals on probation and postrelease control; confirms reasoning in Davis I)
Perry, 10 Ohio St.2d 175 (1967) (parens patriae on res judicata and sentencing limits)