State v. Jackson, 2019 Ohio 1688

In 2016 Trevon Jackson pleaded guilty to having weapons while under a disability and was sentenced to three years of intensive supervised probation.
Jackson violated community-control conditions in 2017; the court gave him another opportunity under community control.
In 2018 Jackson allegedly committed a second violation; he pleaded not guilty and an evidentiary hearing was held.
Hearing testimony (probation officers, deputies, Jackson) showed unauthorized removal from electronic monitoring, threats to a woman, texts and a photo suggesting attempts to obtain a firearm, and failure to submit a drug screen.
The trial court found multiple violations, revoked community control, and resentenced Jackson to 30 months in prison (with credit for time served).
Jackson appealed, arguing the record did not support the revocation and prison sentence because the court failed to consider mitigating evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the record supports revocation of community control and imposition of a 30-month prison term	State: evidence showed multiple violations (electronic-monitoring breaches, attempt to acquire firearm, missed drug test); prison was recommended and appropriate	Jackson: trial court failed to consider mitigating factors (remorse, drug-history acknowledgment, lack of physical harm) and thus record does not support sentence	Affirmed: record supports findings; court considered sentencing principles and mitigating factors; defendant no longer amenable to community control

State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standard for appellate review of felony sentences under R.C. 2953.08(G)(2))
State v. Fraley, 105 Ohio St.3d 13 (Ohio 2004) (after a community-control violation the court conducts a new sentencing hearing and must comply with sentencing statutes)
State v. Bedell, 107 N.E.3d 160 (1st Dist. 2018) (trial court not required to state on the record consideration of every sentencing factor)