State v. Lucas, 2014 Ohio 3857

Lucas was convicted in two Ottawa County cases on March 4, 2013 and sentenced to two 12-month incarcerations consecutively, suspended and converted to a 3-year community-control term.
An August 8, 2013 probation-violation hearing found Lucas admitted to curfew violation and address change, constituting a breach of community control.
On September 16, 2013 the trial court reinstated the suspended sentences in both cases.
Appellant received Anders counsel who filed a brief and advised Lucas he could file his own brief, which he did not do.
Counsel argued two potential errors: (a) validity of the admission to the community-control violation, and (b) whether the sentence was lawful; the court ultimately found no merit in the assignments and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred in accepting the admission to the violation as knowing and voluntary.	Lucas (via counsel) contends admission may not be voluntary.	Lucas contends Crim.R. 11 applies; but the court held Crim.R. 32.3 governs community-control violations.	No error; Crim.R. 32.3 applied.
Whether the sentence was contrary to law.	Lucas argues sentencing exceeded lawful limits or lacked proper consideration.	Court imposed permissible sentence within statutory limits with proper findings.	Sentence within statutory limits and properly justified.
Whether appellate counsel's Anders review was properly conducted and the appeal should be deemed frivolous.	Appellate challenge may have merit; Anders review insufficiently explored issues.	Counsel conducted Anders review and found the appeal frivolous.	Appeal deemed frivolous; counsel’s withdrawal granted.

Anders v. California, 386 U.S. 738 (U.S. (1967)) (review of the merits when counsel seeks to withdraw in an appeal)
State v. Martin, 2002-Ohio-5202 (6th Dist. Sandusky (2002)) (Crim.R. 32.3 governs community-control violations; Crim.R. 11 not applicable)