State v. King, 2020 Ohio 1512

King pled guilty to two fourth-degree felonies (drug trafficking and improper handling of a firearm) plus a firearm specification; total sentence 46 months in prison.
On March 9, 2017 the trial court granted judicial release, ordered King released March 16, 2017, and placed him on four years of intensive community control while reserving the right to reimpose the remaining 34 months of the original sentence.
Community-control conditions required weekly in-person reporting to the Bureau of Community Corrections; King last reported on June 1, 2017.
A revocation motion was filed February 11, 2019 alleging failure to comply with community-control conditions; a revocation hearing was held February 27, 2019.
The trial court found King violated his judicial-release conditions and reimposed the suspended balance (2 years, 10 months / 34 months). King appealed, arguing the failure-to-report was only a "technical violation" governed by R.C. 2929.15 and therefore punishable only up to 180 days' imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a failure-to-report while on judicial release permits reimposition of the suspended portion of the original prison term under R.C. 2929.20(K), or whether such a breach is a "technical violation" governed by R.C. 2929.15 with statutory caps on incarceration	The State: R.C. 2929.20 governs revocation of judicial release; the court may reimpose the suspended balance and is not limited by the R.C. 2929.15 technical-violation caps	King: The term "violation" in R.C. 2929.20(K) is ambiguous and should be read to mean only new offenses; a mere failure to report is a technical violation under R.C. 2929.15(B)(1)(c)(ii), capping prison at 180 days	The court held R.C. 2929.20(K) governs judicial-release revocations; "violation" is not limited to new offenses; the trial court properly reimposed the suspended 34-month balance and the sentence is not contrary to law

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (describes the appellate "clear and convincing" standard for reviewing felony sentences under R.C. 2953.08(G)(2)).
Cross v. Ledford, 120 N.E.2d 118 (Ohio 1954) (defines the "clear and convincing" evidence standard).
State v. Dalton, 793 N.E.2d 509 (Ohio App. 2003) (applies R.C. 2929.20 to permit reinstatement of a reduced original prison term upon revocation of judicial release).
State v. Wiley, 772 N.E.2d 160 (Ohio App. 2002) (supports reimposition of original sentence after judicial-release violation).
State v. McConnell, 757 N.E.2d 1167 (Ohio App. 2001) (same: trial court may reinstate reduced prison term on judicial-release revocation).