State v. Pearson, 2011 Ohio 5910

Pearson was indicted for possession and trafficking of crack-cocaine in Highland County on August 19, 2009.
A jury convicted Pearson of trafficking crack-cocaine and possession; the trial court sentenced him to 12 months in prison and ordered court costs.
Pearson appealed, challenging the imposition of court costs and the lack of notice that nonpayment could lead to community service.
R.C. 2947.23(A)(1) requires judgment for costs and informing the defendant about potential community service as work-off for costs.
The trial court did not inform Pearson about possible community service for unpaid costs at sentencing.
The panel majority held this error sustained, vacated the costs-related portion, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to inform about community service for costs was error	Pearson argues omission violated R.C. 2947.23(A)(1).	State contends issue not ripe since no order for community service.	Error found; remand for cost handling or re-sentencing.

Kalish, 120 Ohio St.3d 23 (Ohio Supreme Court 2008) (two-step review for sentencing statutes and rules)
State v. Bryant, 2009-Ohio-5295 (Scioto App. 2009) (ripeness discussions in cost-posture challenges)
State v. Kearse, 2009-Ohio-4111 (Shelby App. 2009) (ripeness and cost-notice issues in sentencing)
State v. Moss, 2010-Ohio-1135 (Franklin App. 2010) (adopted ripeness approach in similar context)
State v. Dismukes, 2011-Ohio-2193 (Washington App. 2011) (continued application of ripeness reasoning)
State v. Slonaker, 2008-Ohio-7009 (Washington App. 2008) (ripeness and notice concerns in sentencing)
State v. Knauff, 2009-Ohio-5535 (Adams App. 2009) (ripeness viewpoint in similar issue)
State v. Welch, 2009-Ohio-2655 (Washington App. 2009) (ripeness considerations in cost-notice context)
State v. Siler, 2011-Ohio-2326 (Ashtabula App. 2011) (discusses ripeness in sentencing challenges)