State v. Jones, 2020 Ohio 3607

Defendant Brooke E. Jones was originally convicted in Harrison County of child endangerment and sentenced to a two‑year prison term suspended in favor of a five‑year community‑control sanction.
About two years later Jones was convicted in Jefferson County of a third‑degree felony and given a three‑year prison sentence.
The Jefferson County conviction constituted a community‑control violation in Harrison County; at the violation hearing the original Harrison County court reimposed the suspended two‑year term and ordered it to run consecutively to the three‑year Jefferson County sentence.
Jones challenged the consecutive designation, arguing the original sentencing court lacked authority to impose a sentence consecutive to a later sentence and that it had not given notice at the original sentencing that the suspended term could be ordered consecutive to a future conviction.
The Seventh District concluded the original sentencing court had authority to reimpose the suspended sentence consecutively and that no specific notice at the original sentencing was required.
Because that ruling conflicts with decisions of the Second and Fifth Districts, the Seventh District granted a motion to certify the question to the Ohio Supreme Court under Article IV, § 3(B)(4).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jones)	Held
Whether the original sentencing court has authority to impose a community‑control revocation sentence to run consecutively to a later sentence	Original court may reimpose the suspended term and order it consecutive to the later sentence	Only the second (later) sentencing court may impose a sentence consecutive to its own sentence	Seventh Dist.: Original sentencing court has that authority (conflicts with 2d & 5th)
Whether the original sentencing entry must notify the defendant that a reimposed revoked sentence could run consecutively to a future conviction	No notice of the possibility of a consecutive order vis‑à‑vis future convictions is required	The original court must provide notice that the suspended sentence could be served consecutively to a later conviction	Seventh Dist.: No such specific notice is required; defendant was on notice the violation could result in the reimposed term

Whitelock v. Gilbane Bldg. Co., 66 Ohio St.3d 594 (1993) (certification to Ohio Supreme Court requires an actual inter‑district conflict on a rule of law and the certifying opinion must identify that rule)