State v. Reed, 2023 Ohio 1161

Reed was indicted for aggravated robbery, kidnapping, and robbery; she pled guilty to aggravated robbery and received up to five years of community control (other counts and firearm specs dismissed).
The trial court imposed multiple community-control conditions and added further sanctions over time; Reed’s case was later transferred to Women’s Therapeutic Court.
Probation filed a revocation notice (May 31, 2022) alleging Reed violated case-plan objectives, violated a no-contact order with Tyler Gray, and was discharged from sober living; the notice informed her of rights including a probable-cause hearing.
At the June 22, 2022 hearing Reed, represented by counsel, admitted she failed to comply with case-plan objectives by being discharged from sober living and waived a separate probable-cause hearing; the court revoked community control and sentenced her to 5 to 7.5 years in prison.
On appeal Reed argued (1) the revocation violated due process because the notice was vague and hearings were combined, and (2) trial counsel rendered ineffective assistance by failing to object and by not presenting mitigation. The appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation complied with due process (adequacy of notice; preliminary vs final hearing; knowing waiver)	State: Notice and hearing met Gagnon/Morrissey requirements; Reed admitted violation, so rights were effectively waived	Reed: Notice was vague about which condition was breached; court improperly combined preliminary and final hearings; waiver was not knowing and intelligent	Court: Notice was sufficient, Reed knowingly admitted violation and waived a separate probable-cause hearing; no due-process or plain-error relief granted
Whether counsel provided ineffective assistance at revocation/sentencing	State: Counsel was not ineffective; Reed’s admission left little for adversarial testing; no evidence counsel’s conduct rendered admission involuntary	Reed: Counsel failed to object to notice vagueness, lack of probable cause hearing, and failed to present mitigating evidence	Court: No deficient performance shown and no prejudice established; ineffective-assistance claim fails

Morrissey v. Brewer, 408 U.S. 471 (1972) (due-process standards for parole/probation revocation proceedings).
Gagnon v. Scarpelli, 411 U.S. 778 (1973) (requirements for preliminary and final revocation hearings).
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel).
State v. Long, 53 Ohio St.2d 91 (1978) (plain-error standard in Ohio criminal appeals).
State v. Bradley, 42 Ohio St.3d 136 (1989) (Ohio’s adoption and application of Strickland standard).
State v. Hale, 119 Ohio St.3d 118 (2008) (prejudice standard referencing Strickland).
State v. Hylton, 75 Ohio App.3d 778 (1991) (Ohio appellate discussion that revocation need not be proved beyond a reasonable doubt; substantial-evidence standard applies).