State v. Nelson, 124 N.E.3d 450

John Edward Nelson pleaded guilty in 2016 to multiple drug-related felonies (trafficking, attempted aggravated trafficking, and two counts of corrupting another with drugs) and was sentenced to four years of community control with standard and special conditions.
The sentencing entry warned that revocation of community control could result in specified prison terms totaling 34 months (17 months on four counts, with certain counts run concurrently and others consecutively).
A special condition prohibited Nelson from having contact with J. Elliott (a known trigger for his alcohol use); his supervising officer also warned him not to associate with her.
On December 23, 2017, Nelson, while intoxicated, kicked in a door at a residence, was arrested, and later convicted in municipal court of criminal damaging; he admitted in a written statement and at the revocation hearing to contact with Elliott and to drinking.
The probation officer filed a supervision-violation notice alleging (1) property damage, (2) contact with Elliott in violation of the no-contact order, and (3) disorderly conduct; the trial court found probable cause and held a community-control-violation hearing.
The trial court revoked community control, found the violations were non-technical, and imposed the full aggregate prison term of 34 months; Nelson appealed arguing the sentence violated R.C. 2929.15(B)(1)(c)(ii)’s post-September 2017 limitations on prison terms for technical or misdemeanor violations.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Nelson)	Held
Whether R.C. 2929.15(B)(1)(c)(ii) limited prison exposure after revocation to 180 days because Nelson’s violations were technical or misdemeanors	The violations were non-technical and not merely minor; statute targets single-felony scenarios and doesn’t prohibit "stacking" of multiple felony sentences on revocation	Nelson contends the statute, as amended (2017 H.B. 49), caps prison for technical or misdemeanor violations arising from a community-control term for a 4th-degree felony at 180 days, so his consecutive 34-month sentence is unlawful	Court held the violations were non-technical (special, rehabilitative no-contact condition), R.C. 2929.15(B)(1)(c)(ii) did not apply, and the 34-month sentence was lawful

None of the appellee’s cited authorities in the opinion have official reporter citations provided in the opinion; the court relied principally on appellate decisions discussing the meaning of "technical violation," including State v. Cozzone, State v. Mannah, State v. Davis, State v. Cearfoss, State v. Jenkins, and Amburgey v. Ohio Adult Parole Authority, for the proposition that some non-criminal violations (particularly those tailored as substantive rehabilitative conditions) are not "technical." (No official reporter citations were provided in the opinion.)