State v. Satterwhite
2017 Ohio 223
| Ohio Ct. App. | 2017Background
- Defendant Arnold Satterwhite pled no contest to one count of heroin possession (felony V) on Sept. 30, 2014; cocaine charge was dismissed. Court imposed five years of community control with multiple conditions (treatment, employment verification, 50 hours community service, abstain from drugs, attend panels, child-support verification, etc.).
- Satterwhite missed required meetings and classes, failed to verify employment, tested positive for benzodiazepines without verifying a prescription, and fell behind on child support.
- Supervision officer Brandon Hayes testified to these violations at a revocation hearing; the court found Hayes credible and Satterwhite not credible.
- On April 29, 2016 the trial court revoked Satterwhite’s community control and imposed a nine-month prison sentence.
- Appellate counsel filed an Anders brief asserting no meritorious issues; the court notified Satterwhite, received no pro se brief, and conducted an independent review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether revocation of community control was supported by substantial evidence | State: supervision testimony showed failures to verify employment, positive drug test without prescription verification, missed classes and panels, and delinquent child support | Satterwhite: missed work due to health, had prescriptions/medication explanations, attended some programs but lacked paperwork, and was told by a counselor not to attend a panel | Court: No abuse of discretion — substantial evidence supported revocation; trial court credibly found State’s witnesses and revoked supervision |
| Standard of proof required at revocation hearing | State: only substantial evidence required, not beyond a reasonable doubt | N/A (defendant implicitly disputed sufficiency) | Court applied substantial-evidence standard and found it satisfied |
| Adequacy of appellate review under Anders | Appellate counsel: no arguable issues exist | Satterwhite: filed no pro se brief | Court independently reviewed the record and found no meritorious error; affirmed |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (U.S. 1967) (procedural framework for counsel’s submission when asserting no meritorious appellate issues)
- State v. Hylton, 75 Ohio App.3d 778 (Ohio Ct. App. 1991) (revocation hearings require only substantial evidence of violation, not proof beyond a reasonable doubt)