State v. Nelson (Slip Opinion), 165 N.E.3d 1110

Defendant John E. Nelson pleaded guilty in 2016 to four fourth-degree drug felonies and was sentenced to community control with standard conditions (obey laws; follow orders of supervising officer; conduct himself as a law‑abiding citizen).
His supervising officer issued a verbal no‑contact order forbidding contact with Jamie Elliott after learning she had been a factor in Nelson’s drinking and prior misconduct.
On December 23, 2017 Nelson drank with Elliott, returned intoxicated to his aunt’s house, damaged a door, was arrested, and later convicted of criminal damaging (a misdemeanor).
The trial court found Nelson violated multiple community‑control conditions, revoked community control, and imposed the 34‑month prison sentence the court had warned Nelson it could impose at original sentencing.
The Second District affirmed, concluding the no‑contact violation was not a “technical violation” and therefore the 180‑day cap in R.C. 2929.15(B)(1)(c)(ii) did not apply. The Ohio Supreme Court affirmed.

Issue	Plaintiff's Argument (Nelson)	Defendant's Argument (State)	Held
Meaning of “technical violation” in R.C. 2929.15(B)(1)(c)(ii)	"Technical violation" means noncriminal, administrative/parole‑type breaches (so the caps apply to any non‑felony/noncriminal violation)	"Technical" denotes minor/admin requirements distinct from substantive, rehabilitative conditions; context and ordinary meaning matter	The term does not turn on whether conduct is criminal; a violation is nontechnical when it is a substantive rehabilitative condition or specifically tailored to address conduct that contributed to the offense; technical violations are akin to administrative supervision requirements.
Whether Nelson’s no‑contact violation was a “technical violation”	Nelson: his violations were non‑felonies/technical, so sentencing capped at 180 days	State: the no‑contact order was tailored to Nelson’s alcohol‑related recidivism risk and thus was a substantive rehabilitative condition; violation nontechnical	Court held the no‑contact violation was nontechnical (specifically tailored to address substance‑abuse risk), so the 180‑day cap did not apply and the longer sentence was permissible.

State ex rel. Taylor v. Ohio Adult Parole Auth., 66 Ohio St.3d 121 (1993) (parole context quotation describing ‘‘technical violations’’ as noncriminal breaches)
State v. Vanzandt, 142 Ohio St.3d 223 (2015) (statutory interpretation principles; de novo review)
D.A.B.E., Inc. v. Toledo‑Lucas Cty. Bd. of Health, 96 Ohio St.3d 250 (2002) (read statutory words in context; presume legislature intended entire statute to be effective)
Federal Communications Comm’n v. AT&T Inc., 562 U.S. 397 (2011) (terms must be read in context; generic parsing of individual words may be inapt)