State v. Langford, 2016 Ohio 456

Rhonda Langford pled guilty (June 18, 2015) to one count of trafficking in drugs (Alprazolam), a fifth-degree felony, for a February 19, 2013 undercover sale.
Trial court ordered a presentence investigation and sentenced Langford to 11 months in prison (78 days jail credit) on August 3, 2015 after finding she was not amenable to community control.
Langford had prior felony convictions and served prison time in Kentucky for multiple offenses; she acknowledged those convictions at plea.
The trial court’s sentencing entry and oral statements recited consideration of R.C. 2929.11 and 2929.12 and balanced seriousness/recidivism factors, citing jail behavior violations as evidence she would not comply with supervision.
Langford appealed, arguing the court failed to make proper findings and did not adequately consider R.C. 2929.11/2929.12 before imposing prison rather than community control.
The appellate court affirmed the sentence as within statutory discretion but reversed and remanded limitedly because the court failed to properly advise and impose postrelease control at the sentencing hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by imposing prison rather than mandatory community control for a 5th-degree felony	State: Court properly exercised discretion under R.C. 2929.13(B)(1)(b) since exceptions applied and sentencing complied with R.C. 2929.11/2929.12	Langford: Trial court failed to adequately consider the purposes/principles of sentencing and the R.C. 2929.12 factors before imposing prison	Held: Affirmed. Community-control presumption did not apply because Langford had prior felonies; court properly considered sentencing factors and permissibly sentenced to prison
Whether postrelease-control was properly imposed and explained at sentencing	State: (implicit) postrelease control was intended and noted in entry/hearing	Langford: Court failed to advise her of discretionary postrelease control and consequences of violation as required by R.C. 2929.19/2967.28	Held: Reversed in part and remanded for limited correction under R.C. 2929.191 because court did not properly notify Langford at the hearing; postrelease-control portion void without correction

State v. Fischer, 128 Ohio St.3d 92 (Ohio 2010) (failure to properly advise offender of postrelease control renders that portion of the sentence void)
State v. Singleton, 124 Ohio St.3d 173 (Ohio 2009) (statutory remedy under R.C. 2929.191 allows trial court to correct postrelease-control imposition errors)