State v. O'Mara, 2024 Ohio 757

Kristi Lynn O’Mara was indicted for two counts of aggravated possession of methamphetamine after being found with the substance during a traffic stop.
Throughout pretrial proceedings, O’Mara repeatedly violated bond conditions, mainly by failing to submit urine samples and attend mandated counseling or assessments.
O’Mara ultimately entered a no contest plea to one count, with the State agreeing to recommend community control if she complied with bond and did not incur new charges.
At sentencing, the trial court found that O’Mara had continued to violate bond, was noncompliant with court orders, and appeared to deflect responsibility, leading to an eight-month prison sentence.
O’Mara appealed the sentence, arguing for community control sanctions instead of prison, but completed her sentence while the appeal was pending and was not subject to post-release control or further court supervision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the prison sentence an abuse of discretion when community control was available?	O’Mara argued she should have received community control and that urine sample failures were due to denied blood test requests.	State argued appeal was moot since O’Mara completed sentence and was not subject to further supervision.	Appeal dismissed as moot because no relief could be provided once sentence was served and no collateral consequences were shown.

State v. Wilson, 41 Ohio St.2d 236 (an appeal is moot when sentence is completed and no collateral consequence exists)
State v. Golston, 71 Ohio St.3d 224 (an appeal of a felony conviction is not moot based solely on sentence satisfaction, but appeals as to sentence alone can be moot if no collateral disability is implicated)
State v. Clinton, 2022-Ohio-717 (an appeal from a completed sentence is moot if post-release control is not imposed and no collateral disability is claimed)
In re S.J.K., 114 Ohio St.3d 23 (collateral disability means an adverse legal consequence surviving after sentence service)