State v. Hope, 2019 Ohio 3023

Dylan A. Hope pled guilty to one count of fourth-degree grand theft of a motor vehicle and was placed in an intervention-in-lieu-of-conviction program based on his documented drug addiction.
After initial program placement and subsequent violations, the court sentenced him to three years of community control in April 2015 and reserved an 18-month prison term in the event of future violations.
Over several years Hope admitted to multiple community-control violations: missed reporting, positive marijuana screens, failure to complete required programs, and failure to pay restitution.
On September 28, 2018, Hope admitted to failing to report to probation and testing positive for marijuana.
At the November 2, 2018 disposition hearing the trial court concluded Hope was no longer amenable to community control and imposed a 16-month prison sentence over defense objection that R.C. 2929.15(B)(1)(c)(ii) limited imprisonment to 180 days for a "technical" violation.
The Sixth District affirmed, reasoning the drug-test violation was a nontechnical breach of a specifically tailored, rehabilitative condition tied to the underlying offense and addiction, so the 180-day statutory cap did not apply.

Issue	Appellant's Argument	State's Argument	Held
Whether a failure to report and a positive marijuana test are "technical" violations under R.C. 2929.15(B)(1)(c)(ii) limiting prison to 180 days	Hope: Violations were technical/noncriminal, so sentence capped at 180 days	State: Violations (especially positive drug screen) were nontechnical because they breached a rehabilitative condition tailored to his addiction and offense	Held: Violations were nontechnical; court may impose more than 180 days (affirmed)

None with official reporter citations (appellate decisions cited in the opinion were regional/unreported or cited by Ohio entry number).