State v. Middlebrooks, 2011 Ohio 4534

On October 15, 2008, Middlebrooks was sentenced to three years of community control for seven counts of trafficking in drugs.
Conditions included restitution of $630 to a drug task force fund, maintaining employment, and abiding by laws.
In January 2010, Middlebrooks was arrested for trafficking and possession of cocaine, and was later convicted of possession of cocaine, a fifth-degree felony.
A July 10, 2010 probation revocation hearing addressed alleged probation violations, including address/employment reporting failures and failure to pay financial obligations.
On July 13, 2010, the trial court found violations and imposed eight-month consecutive sentences on the seven trafficking counts; Middlebrooks appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the sentencing entries final and appealable?	Middlebrooks challenged finality of the judgment entries.	Middlebrooks argued the entries were not final appealable orders.	Appellant withdrew the first assignment; issue moot.
Was there substantial proof of probation violations?	State contends substantial proof supports violations.	Middlebrooks contends proof was insufficient and court abused discretion.	No abuse; substantial evidence supports violations.
Were probation conditions overly broad or lacking nexus to the crimes?	Conditions reasonably related to rehabilitation and future conduct.	Conditions were overly broad and lacked nexus to conviction.	Conditions are not overly broad and are related to the offenses and goals of probation.
Did Middlebrooks receive ineffective assistance of counsel?	Counsel preserved arguments adequately; no ineffective assistance shown.	Counsel provided ineffective assistance in preservation or presentation of arguments.	No reversible ineffective assistance; arguments considered on the merits.

State v. Pavlich, 2011-Ohio-802 (6th Dist., 2011) (probation revocation requires substantial, not beyond reasonable doubt, proof)
State v. Ryan, 2007-Ohio-4743 (3d Dist., 2007) (substantial evidence standard for probation violations)
State v. Hylton, 75 Ohio App.3d 778 (Ohio App.3d, 1991) (probation-violation proof standard referred to in determining revocation)
State v. McKeithen, 2009-Ohio-84 (3d Dist., 2009) (due-process requirements for revocation hearings (Morrissey lineage))
State v. Jones, 49 Ohio St.3d 51 (Ohio, 1990) (broad discretion in imposing probation conditions; relation to justice and rehabilitation)