State v. Hobby, 2017 Ohio 6957

Jason R. Hobby was indicted for one count of fifth-degree felony possession of heroin and pleaded guilty on December 20, 2016.
Hobby failed to appear for the originally scheduled sentencing; a bench warrant issued and sentencing occurred February 22, 2017.
The trial court sentenced Hobby to the maximum 12 months imprisonment (statutory range for a fifth-degree felony), three years discretionary post-release control, and $40 restitution.
The court considered Hobby's prior prison terms (2010, 2011), pending charges in Ashland County, positive drug screens while on bond, failure to report to pretrial release, failure to pay required fees, and failure to appear for sentencing.
Hobby appealed, arguing the 12-month maximum sentence was contrary to law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a 12‑month maximum sentence for a fifth‑degree felony is contrary to law	State: sentence within statutory range and supported by record factors	Hobby: 12‑month maximum is excessive/contrary to law	Affirmed — sentence is within statutory range and record supports consideration of R.C. 2929.11/2929.12 factors

State v. Kalish, 896 N.E.2d 124 (Ohio 2008) (explains post‑Foster appellate review framework for felony sentences)
State v. Foster, 845 N.E.2d 470 (Ohio 2006) (severed portions of R.C. 2929.14 requiring judicial fact‑finding; trial courts have discretion within statutory ranges)
State v. Mathis, 846 N.E.2d 1 (Ohio 2006) (clarifies sentencing post‑Foster and role of statutory guidance)
State v. Payne, 873 N.E.2d 306 (Ohio 2007) (addresses sentencing discretion and appellate review post‑Foster)