State v. Hughes, 2014 Ohio 1320

Appellant Hughes was indicted in Butler County for grand theft and identity fraud related to a July 2012 test drive of a car using false ID and stolen license.
She was arrested in Franklin County, released on bond, and failed to report to the Butler County Clerk within five days of release as required by her Franklin County bond.
Appellant was rearrested, posted a second bond, and later pled guilty to one count of grand theft and one count of identity theft (both fifth-degree felonies).
At sentencing, the trial court imposed nine-month prison terms for each Count, to be served concurrently.
Appellant argued the court should have imposed community control under R.C. 2929.13(B)(1)(a) due to the fourth/fifth-degree non-violent nature of the offenses.
The appellate court reviewed the sentence under R.C. 2953.08(G)(2) and upheld the prison terms, finding the court could impose a term due to bond violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prison terms were proper under RC 2929.13(B)(1)(b)	Hughes urges community control due to non-violent felonies.	Hughes contends no bond-violation justification for prison term.	Court could impose prison term for bond violation; not contrary to law.

State v. Crawford, 2013-Ohio-3315 (12th Dist. Clermont No. CA2012-12-088 (2013)) (clarifies appellate review under 2953.08(G)(2))
State v. Olvera, 2013-Ohio-3992 (12th Dist. Butler No. CA2012-10-199 (2013)) (limits on appellate review of sentencing)
State v. Pearce, 2013-Ohio-3484 (12th Dist. Clermont No. CA2013-01-001 (2013)) (appellate standards for sentencing reversal)
State v. Hughey, 2013-Ohio-4155 (10th Dist. Franklin No. 13AP-135 (2013)) (presumption of community control for certain felonies)
State v. Spencer, 2013-Ohio-137 (3d Dist. No. 6-12-15 (2013)) (limitations and exceptions to community-control presumption)
State v. Ramey, 2012-Ohio-2904 (132 Ohio St.3d 309 (2012)) (bond violations as a basis for prison terms)