State v. McAbee, 2016 Ohio 8234

Edward P. McAbee was indicted (June 2013) on burglary, petty theft, and theft; he pled guilty (Oct. 2013) to attempted burglary (4th-degree felony) and theft (5th-degree felony).
At sentencing (Nov. 2013) the court imposed 6 months' prison on Count One (attempted burglary) and a stayed maximum 6-month CBCF term plus 3 years' community control on Count Three (theft); the court warned PRC could apply for Count One and that a CCV could result in imposition of the 12-month term on Count Three.
The sentencing entry specified that if McAbee violated community control on Count Three, he would be ordered to serve 12 months in prison on that count.
Parole filed a CCV complaint (Feb. 2016); McAbee admitted to three violations (Mar. 2016) and at sanctions (Apr. 2016) the court revoked community control and imposed the 12-month prison term on Count Three, to run consecutive to the earlier Count One term.
The court found consecutive service was not disproportionate, McAbee posed a danger to the public, and consecutive terms were necessary to protect the public given his criminal history; McAbee received jail-credit leaving ~125 days remaining.
McAbee appealed, arguing the trial court erred by imposing the 12-month sentence consecutive to the prior prison term because the original entry did not reserve or make findings about consecutive sentences and he was not warned he could serve more than 12 months total.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by imposing a 12‑month prison sanction on Count Three to run consecutive to the prior prison term after revoking community control	State: Court properly imposed the previously‑admonished 12‑month sanction and found consecutive service justified at the CCV sanction hearing	McAbee: Original sentencing did not reserve or make findings allowing consecutive service later or warn he could serve more than 12 months total	Appeal is moot; McAbee already served the sentence and does not challenge the underlying conviction, so no live remedy — appeal dismissed

State v. Golston, 71 Ohio St.3d 224, 643 N.E.2d 109 (Ohio 1994) (a convicted felon retains a substantial stake in the conviction after sentence satisfaction)
State v. Campbell, 166 Ohio App.3d 363, 850 N.E.2d 799 (Ohio Ct. App. 2006) (challenge solely to sentence length is moot once sentence is served absent challenge to conviction)