State v. Morgan, 2014 Ohio 5071

Defendant Michele Morgan was convicted of grand theft (felony, fourth degree) and received five years of community control with multiple conditions.
The conditions required full-time employment, participation in intensive probation, and attendance at Goodwill Industries or the Bureau of Vocational Rehabilitation.
Morgan appealed the conviction, which this court subsequently affirmed in 2013.
A notice of revocation for community control violations was filed on February 20, 2013, for failure to show employment, attend Goodwill, and report to probation.
A second revocation hearing was held after continued noncompliance, leading to a revocation of community control and a ten-month prison sentence in March 2014.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Morgan’s revocation of community control supported by substantial evidence?	State contends there was substantial evidence of noncompliance.	Morgan argues partial compliance and mitigating factors; due process required fuller consideration.	Yes; revocation affirmed, substantial evidence supported the court's decision.

State v. Harmon, 2008-Ohio-6039 (2d Dist. Champaign (2008)) (due process safeguards for revocation hearings; preliminary and final hearings required)
Morrissey v. Brewer, 408 U.S. 471 ((1972)) (due process framework for probation revocation)
State v. Hatton, 2014-Ohio-3354 (2d Dist. Montgomery (2014)) (probation revocation requires notice, opportunity to be heard; substantial evidence standard)
State v. Cofer, 2009-Ohio-890 (2d Dist. Montgomery (2009)) (support for substantial-evidence standard in community-control revocation)
State v. Eversole, 2010-Ohio-1614 (2d Dist. Montgomery (2010)) (abuse-of-discretion standard; credibility determinations respected)