State v. Hudson, 2019 Ohio 5136

Franklin C.P. grand jury indicted Michael A. Hudson for two counts of fourth-degree assault and one count of fifth-degree obstructing official business based on an October 18, 2017 altercation with two Columbus police officers.
Competency issues arose; Hudson was evaluated at Netcare Forensic Psychiatry Center, stipulated competent, and the trial court found him competent to stand trial.
Hudson pleaded guilty to obstructing official business in exchange for a nolle prosequi on the assault counts; prosecution recited that Hudson slipped handcuffs, struggled in the cruiser, bit an officer, and scuffled, injuring an officer’s leg.
PSI disclosed Hudson’s prior felony convictions, ongoing mental-health treatment, and a statement expressing hostility toward police ("I understand why people shoot cops in the face at stop signs now").
At sentencing the court imposed a four-year community-control term (intensive supervision on the mental-health docket), required continued mental-health treatment, and barred firearm possession; prosecution had sought prison time.
Appellate counsel filed an Anders brief asserting no non-frivolous sentencing issue; this Court conducted an independent Anders review and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence is unsupported by the record or contrary to law	State argued sentence (4 years community control, mental-health supervision, no firearms) was lawful and appropriate	Hudson (via Anders brief) asserted no non-frivolous sentencing claim; potential challenge was that sentence was improper	Court held sentence was supported by record, within statutory range, and not contrary to law; affirmed
Whether appellate counsel complied with Anders and whether any non-frivolous issues exist	State argued Anders brief sufficed and no meritorious issues exist	Hudson had opportunity to file pro se supplement but did not	Court found Anders procedures satisfied, independent review revealed no non-frivolous issues; counsel allowed to withdraw

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures when appointed counsel seeks to withdraw as frivolous)
State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standard for vacating or modifying felony sentence: clear and convincing evidence)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse of discretion defined as unreasonable, arbitrary, or unconscionable)
Cross v. Ledford, 161 Ohio St. 469 (Ohio 1954) (definition of clear and convincing evidence)
State v. Jones, 49 Ohio St.3d 51 (Ohio 1990) (community-control conditions cannot unduly infringe liberty)
State v. Amos, 140 Ohio St.3d 238 (Ohio 2014) (policy favors community-control sanctions for low-level felonies)
State v. Talty, 103 Ohio St.3d 177 (Ohio 2004) (trial court may impose community-control sanctions when prison is not required)