State v. Oulhint, 2013 Ohio 3250

Appellant Abdelaziz Oulhint pleaded guilty to one count of grand theft and was advised at plea that a prison term would carry discretionary post-release control up to three years.
At sentencing the court imposed 18 months of community control (probation) with conditions rather than a prison term; the court warned that violation could result in a prison term up to 18 months.
Oulhint violated community control multiple times (positive drug tests, municipal theft convictions, program misconduct, failure to comply with treatment/fees).
After an initial violation (parties waived a hearing), the court continued community control; at a later violation hearing the court found Oulhint in violation and imposed an 8-month prison sentence.
Oulhint appealed, arguing (1) the trial court failed to advise him of post-release control at the sentencing hearing and thus he is entitled to a de novo sentencing hearing, and (2) the court did not properly notify him at the violation stage or in the journal entry of the specific prison term that could be imposed for violating community control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to advise of post-release control at the original sentencing (which imposed community control) requires de novo sentencing	State: No de novo hearing required because post-release control must be advised only when a prison term is imposed at sentencing	Oulhint: Court failed to notify him of post-release control at sentencing, so the sentence is defective and requires de novo resentencing	Court held no error: advising of post-release control is required when imposing a prison term at original sentencing, not when community control is imposed; defendant was advised at plea of possible post-release control if later sentenced to prison
Whether the court had to notify defendant at the first violation hearing or in the journal entry of the specific prison term that could be imposed on future violation	State: Original sentencing hearing and entry already advised defendant of specific 18-month maximum; no need to repeat at later violation or in the first violation entry	Oulhint: Court failed to notify him at the first violation hearing or in the violation entry that prison could be imposed later, so imposition of prison at later violation was improper	Court held no error: original sentencing hearing included notice of the specific prison term (18 months), so the court was not required to re-notify at subsequent violation proceedings

State v. Fraley, 821 N.E.2d 995 (Ohio 2004) (holding a trial court that failed to notify a defendant at original sentencing of the specific prison term that could follow a community-control violation may cure that failure by advising the defendant at a subsequent violation hearing)