State v. Holloway, 91 N.E.3d 38

In Aug. 2015 Holloway pled guilty to attempted failure to register address as a Tier I sex offender (5th-degree felony).
Oct. 2015 trial court sentenced him to five years community control and expressly "reserved a 12-month prison term" if he violated conditions.
Mar. 2016 probation reported a registration violation; court found a violation but continued community control, warning of a "zero tolerance" policy and again referencing the 12-month term.
July 2016 Holloway was found to have a new violation (robbery conviction); the court revoked community control and imposed the previously reserved 12-month prison term.
Holloway appealed, arguing the court erred because it failed to advise him of the specific 12-month term in strict compliance with R.C. 2929.19(B)(4) at the original sentencing or at subsequent violation hearings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with R.C. 2929.19(B)(4) by notifying Holloway of the specific prison term that could be imposed for community-control violations	State: Trial court properly notified Holloway that a 12-month term was reserved and could be imposed on violation	Holloway: Notification was not in strict compliance; court did not explicitly advise of the specific 12-month term at original or each subsequent violation hearing	Court: Notification was sufficient — trial court explicitly reserved a 12-month term at original sentencing and referenced it at the later hearing; imposing the 12-month term on revocation was proper

State v. Brooks, 103 Ohio St.3d 134 (Ohio 2004) (trial court must notify offender of the specific prison term that may be imposed for a community-control violation)
State v. Fraley, 105 Ohio St.3d 13 (Ohio 2004) (notification timing: original sentencing required for first violation; R.C. 2929.15(B) violation hearing governs notification for subsequent violations)