State v. Reese, 2021 Ohio 1407

Reese previously served six years for aggravated robbery, burglary, and kidnapping and was on postrelease control after prison.
He was charged with escape after failing to report to his parole officer in December 2018; pleaded guilty to one count of escape (fourth-degree felony) in December 2019.
In January 2020 the court imposed one year of community control requiring completion of a CBCF program and weekly telephone contact with his probation officer.
Reese completed the CBCF program and called his PO once on June 10, 2020; he was instructed to call weekly but failed to call for five consecutive weeks.
A capias issued, Reese was arrested, and the trial court revoked community control and sentenced him to 15 months in prison for the violation.
Reese appealed, arguing the missed calls were a "technical" violation subject to R.C. 2929.15’s 180-day cap; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failing to call a probation officer weekly is a "technical violation" subject to R.C. 2929.15’s 180‑day cap	State: the weekly-call requirement was a substantive rehabilitative condition tied to supervision and nontechnical	Reese: missing the required calls was a mere technical/administrative violation and sentencing must be capped at 180 days	The court held the violation was nontechnical (substantive rehabilitative); sentencing caps do not apply

State v. Nelson, 160 Ohio St.3d 27 (2020) (adopts totality‑of‑circumstances test to distinguish technical administrative violations from substantive rehabilitative conditions)
State v. Neville, 128 N.E.3d 937 (8th Dist. 2019) (failure to report for months is nontechnical; a single missed report may be technical)
State v. Black, 142 Ohio St.3d 332 (2015) (statutory words receive their common, ordinary meaning)
State v. Pariag, 137 Ohio St.3d 81 (2013) (statutory interpretation is reviewed de novo; courts seek legislative intent)