State v. Longworth, 2011 Ohio 4191

In 2005, Longworth was convicted of felonious assault and sentenced to community control for up to five years with various conditions.
The sentencing entry warned that a violation could result in a two-year prison term.
A CCS officer later reported being unaware of Longworth’s whereabouts, leading to a capias and finding him an absconder in 2005.
Longworth was not arrested until September 14, 2010, after which a CCS revocation hearing occurred and he was sentenced to two years in prison.
A Notice of CCS Revocation Hearing informed Longworth of rights, including the right to a probable cause hearing and to present evidence.
Longworth challenged the revocation in two assignments of error: (1) due process rights were violated; (2) the court erred by disapproving the transfer to transitional control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the revocation violate due process rights?	State argues due process was satisfied under Gagnon standards.	Longworth contends he was not directly advised of rights and thus due process was violated.	No plain error; due process satisfied under Gagnon requirements.
Was the transfer to transitional control improperly disapproved in the sentencing entry?	State concedes error on the transitional-control language.	Longworth argues the court properly disapproved the transfer in the termination entry.	Merit to the second assignment; modify sentence by removing transitional-control disapproval.

Gagnon v. Scarpelli, 411 U.S. 778 (Supreme Court, 1973) (two due process requirements for probation revocation)
State v. Gardner, 118 Ohio St.3d 420 (Ohio Supreme Court, 2008) (plain-error review requires prejudice from lack of notice)
State v. Jones, 116 Ohio St.3d 211 (Ohio Supreme Court, 2007) (prejudice required for plain-error in probation cases)