State v. Lowery, 2016 Ohio 7701

Myra Lowery was convicted of misdemeanor assault in Chillicothe Municipal Court (Feb 2015) and placed on two years of community control.
While on municipal community control, she was also subject to supervision by the Ross County Common Pleas Court (concurrent supervision situation).
Probation filed a violation complaint (Nov 17, 2015); revocation hearing occurred Jan 29, 2016, where Lowery moved to dismiss for lack of jurisdiction under R.C. 2951.022.
The municipal court denied the motion, found a violation, and sentenced Lowery to 30 days in jail (credit 2 days) but left community control in place until Feb 27, 2017.
Lowery appealed the denial of her motion to dismiss; the appellate record shows no stay of execution and it appears Lowery already served the 30-day jail term.
The Fourth District held the appeal moot because no effective relief could be granted and dismissed the appeal without resolving the jurisdictional question.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the municipal court had subject-matter jurisdiction to revoke community control of a concurrent-supervision offender under R.C. 2951.022	The State: an intercourt agreement between Ross C.P. and Chillicothe Municipal Court authorized supervision by the sentencing municipal court, so the municipal court had jurisdiction	Lowery: R.C. 2951.022 requires supervision by the court imposing the longest possible sentence (the common pleas court) absent an agreement; no such agreement is in the record	Not decided on merits — court declined to reach jurisdiction because the appeal was moot (Lowery had served the jail term)
Whether the appeal is moot and thus non-justiciable	The State implicitly argued the case could proceed because an agreement existed	Lowery did not claim a collateral disability or other ongoing injury from the revocation that would preserve the appeal	Held moot: because Lowery already served the full 30-day sanction and showed no collateral consequences, the court dismissed the appeal and did not address jurisdictional merits

State v. Wilson, 41 Ohio St.2d 236 (rule that an appeal is moot when sentence fully served absent collateral disability)
State v. Berndt, 29 Ohio St.3d 3 (burden on appellant to show inference of collateral disability to avoid mootness)
State v. Golston, 71 Ohio St.3d 224 (felony convictions may avoid mootness due to severe collateral consequences)
State ex rel. Hemsley v. Unruh, 128 Ohio St.3d 307 (discussion of subject-matter jurisdiction in community-control context)
Patton v. Diemer, 35 Ohio St.3d 68 (judgment by a court lacking subject-matter jurisdiction is void)