State v. Sanchez, 2021 Ohio 1593

In Jan 2018 police stopped Juan Sanchez, found a loaded handgun, cocaine, marijuana, and a scale; Sanchez had an extensive criminal history and multiple prior community-control violations.
Sanchez pleaded guilty (Mar 2018) to amended drug-possession count and having a weapon while under disability; sentenced to 30 months in prison.
In June 2019 the court granted judicial release and imposed 12 months of community-control sanctions with conditions (regular testing; "no alcohol or drugs"; maintain employment or schooling).
A probation status report showed Sanchez tested positive for marijuana; Sanchez had a medical marijuana card for seizures and presented a physician’s note.
At the March 9, 2020 violation hearing Sanchez (and defense counsel) openly admitted using medical marijuana in violation of his community-control terms and sought mitigation.
The trial court revoked judicial release, reimposed the remainder of the 30-month sentence, and Sanchez appealed claiming a due-process defect for lack of notice that medical marijuana use was prohibited.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation of judicial release violated due process because Sanchez was not properly notified that medical marijuana use would violate his community-control conditions	State: conditions and judgment entry said "no alcohol or drugs," probation has a no-tolerance policy, and Sanchez admitted the violation — substantial proof supports revocation	Sanchez: he was not properly notified that medical marijuana (with a card) would be prohibited; probation officer was unsure whether medical marijuana was allowed	Court: Affirmed. Because Sanchez admitted the violation, the court did not reach the merits of the notice argument; admission provided substantial proof supporting revocation and reimposition of sentence

State v. Westrick, 196 Ohio App.3d 141 (3d Dist. 2011) (judicial-release revocation is not a criminal trial; state must show substantial proof of violation; review for abuse of discretion)
Ruwe v. Bd. of Twp. Trustees, 29 Ohio St.3d 59 (Ohio 1987) (definition of abuse of discretion: unreasonable, arbitrary, or unconscionable)