State v. Salter, 2014 Ohio 5524

In May 2010, Tracy J. Salter pled guilty to one count of failure to comply with an officer's signal or order, a third-degree felony, and was sentenced to four years imprisonment.
In September 2011 the trial court granted Salter judicial release under R.C. 2929.20, placed him on four years of community control, and reserved the right to reimpose the original sentence if he violated conditions.
In November 2013 the probation officer filed a request to revoke community control alleging multiple violations.
The trial court revoked Salter's judicial release and elected to return him to prison, but instead of reimposing the originally imposed four-year term, it imposed a three-year term.
The court reduced the term based on subsequent legislative changes that lowered the maximum sentence for third-degree felonies to three years; the State appealed, arguing the trial court erred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court could reduce an already-imposed sentence on revocation of judicial release	State: Trial court must reimpose the original sentence reserved at judicial-release, not a reduced term	Salter: New statutory maximums apply, allowing reimposition of the lower (three-year) term	Court: Trial court erred; must reimpose original four-year sentence upon revocation

State v. Wiley, 148 Ohio App.3d 82 (Ohio Ct. App. 2002) (trial courts cannot increase original sentence on judicial-release revocation)