State v. Johnson, 2018 Ohio 2387

Jerome A. Johnson committed multiple controlled cocaine buys in Sept. 2016, was indicted on drug offenses, and pled guilty in June 2017.
At sentencing the trial court noted Johnson was on post-release control from prior convictions (trafficking and tampering) and had remaining post-release control time.
The court terminated the post-release control and ordered that the remainder of the post-release-control term be imposed as a mandatory consecutive prison term.
The sentencing entry (nunc pro tunc) directed the remainder of post-release control be converted to a prison term, served consecutively to the new sentence.
Johnson appealed, arguing the trial court erred by failing to notify him at sentencing of the specific amount of time he would be required to serve for the post-release-control violation.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Johnson)	Held
Whether the trial court was required at sentencing to notify the defendant of the specific length of prison time to be imposed for violating post-release control	The trial court need not state the exact time; the court may order imposition of the remainder of post-release control and the Adult Parole Authority may administratively calculate the exact term	The court erred by failing to notify him of the exact amount of time he would be required to serve for the post-release-control termination	The conviction affirmed; no error — the court may order the remainder of post-release control be imposed and the precise term can be administratively determined under R.C. 2929.141

State v. Brooks, 103 Ohio St.3d 134 (2004) (trial courts must notify offenders of the specific prison term that may be imposed for violation of community control at original sentencing)
State v. Fraley, 105 Ohio St.3d 13 (2004) (same principle as Brooks regarding notification at community-control sentencing)