State v. Harris, 2012 Ohio 1304

Harris was convicted of Unauthorized Removal, a first-degree misdemeanor under Youngstown Ordinance 545.23.
He received community control sanctions: 90 days of daily jail reporting, one year of intensive probation, $200 fine, $100 costs, and 74 hours of community service in lieu of the fine.
He failed to report or perform any community service and stipulated to the probation violation.
The trial court revoked probation and sentenced him to 150 days in jail.
On appeal, counsel filed a no-merit brief and a motion to withdraw; the court noted mootness and granted the withdrawal.
The sentence was served, and the appeal was dismissed as moot with no non-frivolous issues remaining.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the appeal moot after service of the sentence?	Harris served the sentence and didn't seek a stay or report collateral consequences.	N/A	Yes; the appeal is moot and dismissed.
Whether the probation revocation proceedings were properly conducted and the sentence within range?	Probation violation proved; sentencing within statutory range.	No abuse of discretion in hearings or sentence.	No abuse; proper proceedings and within range; no meritorious issues.
Whether any non-frivolous issues exist for review?	None	None	No non-frivolous issues; appeal dismissed.

Cleveland Heights v. Lewis, 129 Ohio St.3d 389 (2011) (mootness for misdemeanor appeal; voluntary service of sentence suffices)
State v. Delaine, 2010-Ohio-609 (7th Dist.) (probation revocation requires substantial proof; review of discretion)
State v. Brown, 2010-Ohio-6603 (7th Dist.) (abuse of discretion standard in revocation proceedings)
State v. Maurer, 473 N.E.2d 768 (1984) (abuse of discretion and due process in sentencing)
State v. Smith, 2002-Ohio-6710 (7th Dist.) (due process in probation revocation hearings)