State v. Patterson, 2021 Ohio 3959

Joseph Patterson was indicted for one count of aggravated possession of drugs (fifth-degree felony) and pleaded guilty.
The trial court found Patterson not amenable to community control and sentenced him to 12 months in the Butler County jail under R.C. 2929.34.
The court advised Patterson he could be subject to up to three years of postrelease control and ordered him to pay "costs of prosecution, supervision and any supervision fees permitted pursuant to Revised Code Section 2929.18(A)(4)."
The sentencing entry declined to impose confinement costs; Patterson did not appeal any explicit confinement-cost order in the judgment entry.
Patterson appealed solely arguing (1) he may later be ordered to pay confinement costs under the TCAP statute (R.C. 2929.37(A)), which could bypass the trial court's obligation to consider ability to pay and result in double recovery by the county, and (2) the court erred by imposing supervision costs when he received a maximum prison term and was not sentenced to community control.
The court of appeals affirmed: it held the TCAP/confinement-cost argument was speculative and not ripe for review, and it held supervision costs related to postrelease control are authorized by R.C. 2929.18(A).

Issue	Patterson's Argument	State's Argument	Held
Whether Patterson can be later required to pay confinement costs under TCAP despite the sentencing entry declining confinement costs	TCAP (R.C. 2929.37(A)) allows the county to require payment of confinement costs without the trial court having considered ability to pay, enabling double recovery and bypassing R.C. 2929.18(A)(5)(a)(ii)	No confinement-cost order appears in the appealed judgment; any future TCAP action is speculative and not part of this appeal	Court: Issue is speculative and not ripe; will not review errors outside the appealed judgment; no reversible error in the sentence regarding confinement costs
Whether the court erred by ordering supervision costs when Patterson received a maximum prison term and was not sentenced to community control	Supervision costs should not apply because Patterson received prison time and was not placed on community control	Sentence exposes Patterson to postrelease control; R.C. 2929.18(A) authorizes imposition of costs for sanctions (including supervision) incurred by the government	Court: Supervision costs tied to postrelease control are authorized under R.C. 2929.18(A); no error in imposing supervision costs

State v. Jones, 163 Ohio St.3d 242 (Ohio 2020) (standard of review for felony sentences under R.C. 2953.08(G)(2))
State v. Stambaugh, 34 Ohio St.3d 34 (Ohio 1987) (ripeness/justiciability requires a real controversy)
Burger Brewing Co. v. Liquor Control Comm., 34 Ohio St.2d 93 (Ohio 1973) (principles of justiciability and when a matter is fit for judicial resolution)