State v. Jones, 95 N.E.3d 440

On May 15, 2016, Joseph Jones walked his pit-bull, Prince Bane, unleashed at ~3:30 a.m.; a similar-looking stray accompanied them.
Alyssa Rushing encountered the dogs on her apartment steps; she alleges Prince Bane attacked, biting her hands and pulling her down while she tried to pick up her small dog.
Jones claimed the stray attacked Rushing’s dog and that he subdued the stray; he argued his dog did not bite Rushing.
Jones was charged and convicted under R.C. 955.22(D) for failing to confine a “dangerous dog” (fourth-degree misdemeanor).
The dog had not been previously designated a "dangerous dog" under R.C. 955.11 and no prior notice/hearing under R.C. 955.222 occurred.
The appellate court reversed, holding the dangerous-dog designation is an element of the offense and must precede prosecution under R.C. 955.22(D); Jones was discharged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conviction under R.C. 955.22(D) can stand absent a prior dangerous-dog designation	State: dog’s conduct at incident made it “dangerous,” so owner violated R.C. 955.22(D) without prior designation	Jones: no prior designation or notice/hearing; cannot criminally sanction without R.C. 955.222 process	Court: conviction reversed — prior designation under R.C. 955.11 (and R.C. 955.222 process) is an element and prerequisite
Whether completion of probation moots appeal	State: implicitly contends appeal moot because sentence served	Jones: appeal not moot; still has substantial stake and did not acquiesce	Court: appeal not moot; can reverse conviction though probation served

State v. Cowan, 814 N.E.2d 864 (Ohio 2004) (struck prior dangerous-dog statutory scheme for failing to provide meaningful hearing; due-process concerns)
State v. Grice, 906 N.E.2d 1203 (Ohio Ct. App. 2009) (standard for sufficiency of the evidence review)
Cleveland Heights v. Lewis, 953 N.E.2d 278 (Ohio 2011) (completion of sentence does not necessarily moot an appeal when defendant did not acquiesce)